Privacy Policy

This Privacy Policy (this “Policy”) describes how Pro Hauls LLC, a Tennessee limited liability company doing business as Pro Hauls (“Pro Hauls,” “we,” “us,” or “our”), collects, uses, discloses, retains, and otherwise processes information in connection with the Pro Hauls websites (including https://www.prohauls.co and https://www.prohauls.app and their subdomains and successors), mobile applications, APIs, and related software and services (collectively, the “Platform” or the “Services”).

This Policy is incorporated into the Pro Hauls Terms of Service (the “Terms”). Capitalized terms used but not defined here have the meanings in the Terms. If this Policy and the Terms conflict with respect to personal information, this Policy controls. For all other subjects, the Terms control.

By creating an Account, clicking to accept, signing an Order Form, or accessing or using the Platform, you agree to this Policy. If you do not agree, do not use the Platform.

This Policy is a notice and a commercial allocation of data rights. As between you and Pro Hauls, Pro Hauls owns the Platform Data as stated in Sections 1.1 and 8. It is not a warranty of security, confidentiality, or uninterrupted privacy. It is not a waiver of any privacy right that Applicable Law does not permit to be waived. Statutory consumer, employee, and motor-vehicle privacy rights that cannot be contracted away remain. Pro Hauls collects, owns (as stated), controls, and uses information as stated here and in the Terms.

Privacy, data, TCPA, and location claims against Pro Hauls follow the Terms (including arbitration, class-action waiver, jury waiver, exclusive Tennessee venue, the one-year claim period, and limitation of liability). This Policy does not create a separate private right of action, extra damages, or a longer limitations period. See Section 26.

Pro Hauls LLC is a Tennessee limited liability company with its principal office at 302 Orlando Ave, Nashville, TN 37209. Pro Hauls operates a technology platform used in connection with tri-axle, dump-truck, and related construction-materials hauling logistics.

When Pro Hauls arranges Marketplace transportation of property for compensation, Pro Hauls is performing the functions of a property broker. Pro Hauls LLC is an authorized federal property broker, MC-1812037, USDOT Number 4559499. Pro Hauls is not a motor carrier, not a household-goods broker, not a freight forwarder, and not the employer of Drivers or Operators. Independent Operators perform every physical haul. Collecting a CDL Number, insurance, GPS, or tickets does not make Pro Hauls a carrier or an employer.

Privacy contact (all privacy requests and questions):

Pro Hauls LLC
Attn: Privacy
302 Orlando Ave, Nashville, TN 37209
Email: support@prohauls.co
Phone: 1-800-4PROHAUL (1-800-477-6428)

This Policy applies to the websites prohauls.co and prohauls.app, successor domains, and the Pro Hauls mobile applications (including any Drive or Operator application we publish). The current posting of this Policy is at https://www.prohauls.co/privacy-policy and in the apps.

1.1 PRO HAULS OWNS THE DATA (centerpiece)

PRO HAULS OWNS THE DATA. As between you and Pro Hauls, Pro Hauls owns all Platform Data — including Account and profile data you submit to the Platform; Job, ticket, GPS/Device Data, photos, and chat/SMS content stored on the Platform; Usage Data; Rate Engine inputs, models, weights, outputs, Marketplace Rates, scores, and insights; compilations, databases, schemas, and logs; de-identified and aggregated data; and Feedback. By using the Platform, you assign that data to Pro Hauls LLC to the maximum extent permitted by Applicable Law (with a fallback exclusive license that is the economic equivalent of ownership where assignment is not permitted), subject only to the narrow license-back and compliance carve-outs in Section 8. Ownership of Platform Data is a commercial allocation of rights. It does not waive non-waivable consumer privacy rights, and it does not mean Pro Hauls “owns your body” or can ignore a deletion right that law requires. Details: Section 8.

This Policy applies to information we collect from or about:

• Customers (including contractors, producers, quarries, plants, and other businesses that post Jobs or use Private Fleet tools);
• Operators and Independent Operators (including motor carriers, Non-Asset Brokers, Hired Fleet Operators, and persons who accept Marketplace Jobs);
• Drivers (the individual who physically operates a vehicle, identified by CDL Number);
• Authorized Account Users who log in under a User’s Account;
• visitors to our websites who may not have an Account; and
• other persons whose information a User submits (for example, a Customer’s jobsite contact, a factor, an insurance producer, or a Driver employed or engaged by an Operator).

Most Users interact with Pro Hauls in a commercial, business-to-business capacity. Many individuals whose information we process are acting for a business (an Operator, a Customer, or an employer), not as a consumer shopping for personal use. Tennessee’s Information Protection Act and several other state privacy statutes define “consumer” to exclude a natural person acting in a commercial or employment context. We still provide this Policy, including the TIPA and California chapters, whether or not a particular statute currently applies to a particular person or to Pro Hauls as a “controller” or “business.” Providing this notice is not a concession that any statute applies, that any person is a “consumer,” or that Pro Hauls has waived a statutory exception (including B2B, employee, FCRA, DPPA, or property-broker recordkeeping exceptions).

This Policy does not apply to:

• Pro Hauls employees and job applicants in their HR capacity (those individuals receive any legally required employment notice separately);
• third-party websites, apps, payment processors, mapping providers, FMCSA databases, or other services we do not control; or
• information a User collects about others using the User’s own systems off the Platform.

2.1 User-submitted third-party personal information

If you submit information about another person — including a Driver’s CDL Number, CDL image, medical-examiner certificate, MVR, background-check proof, or a Customer’s jobsite contact, receiver, plant clerk, or dumpsite telephone number — you represent, warrant, and covenant that:

• (a) you have authority to submit that information;
• (b) you have given every notice and obtained every consent Applicable Law requires, including FCRA notices if you procured a consumer report, a DPPA-permitted purpose if you obtained motor-vehicle-record data, location notices if you cause a device to share GPS, and TCPA / state mini-TCPA consent if you give us a number we may call or text;
• (c) that person has been told that Pro Hauls will process the information as this Policy and the Terms describe, including sharing it on a Job, using it for billing, claims, 371 files, and the Rate Engine, and retaining it as Section 10 describes; and
• (d) you will give those people any required notice. Pro Hauls has no duty to notify a Driver, employee, or jobsite contact whom you added.

You shall defend, indemnify, and hold harmless the Pro Hauls Indemnified Parties from claims (including TCPA, FCRA, DPPA, BIPA, state privacy, and publicity-rights claims) arising from your submission of another person’s information or from your failure to notify or obtain consent. This is in addition to Terms Sections 3.5(d) and 9.2.

LOCATION INFORMATION IS REQUIRED TO PERFORM A JOB ON THE PLATFORM. IF YOU ARE AN OPERATOR OR DRIVER ON A JOB, YOU CANNOT OPT OUT OF LOCATION COLLECTION AND STILL PERFORM THAT JOB.

WE COLLECT PRECISE LOCATION INFORMATION FROM THE MOBILE DEVICE, CONNECTED EQUIPMENT, OR OTHER GPS-ENABLED SOURCE ASSOCIATED WITH AN OPERATOR OR DRIVER WHILE THE APPLICATION IS IN USE ON A JOB. IF YOU ENABLE BACKGROUND LOCATION (FOR EXAMPLE, “ALWAYS” OR “ALLOW ALL THE TIME” IN DEVICE SETTINGS), WE MAY ALSO COLLECT LOCATION WHILE THE APPLICATION IS OPEN BUT NOT ON SCREEN, INCLUDING WHILE YOU USE NAVIGATION OR OTHER APPS DURING A JOB. WE MAY DERIVE APPROXIMATE LOCATION FROM IP ADDRESS, CELL TOWERS, WI-FI, GEOFENCES AROUND PLANTS, QUARRIES, JOBSITES, AND DUMPSITES, AND FROM USER-ENTERED ADDRESSES EVEN WHEN GPS IS OFF.

PRECISE LOCATION MAY BE SHARED WITH THE CUSTOMER, THE JOBSITE, THE PLANT OR QUARRY, A RECEIVER, OTHER AUTHORIZED ACCOUNT USERS ON THAT JOB, AND SERVICE PROVIDERS WHO HELP US OPERATE DISPATCH, MAPPING, FRAUD, BILLING, AND THE RATE ENGINE. LOCATION RECORDS ARE PLATFORM RECORDS AND MAY BE USED AS EVIDENCE UNDER THE TERMS.

LOCATION IS NOT OPTIONAL FOR OPERATORS AND DRIVERS ON AN ACTIVE JOB. IF YOU DISABLE LOCATION SERVICES REQUIRED FOR A JOB, WE MAY BE UNABLE TO MATCH, TRACK, TIME, BILL, OR COMPLETE THE JOB, AND WE MAY CANCEL THE JOB OR RESTRICT THE ACCOUNT. CUSTOMERS WHO POST JOBS CONSENT TO OUR COLLECTING AND DISPLAYING LOCATION OF OPERATORS ASSIGNED TO THEIR JOBS, AND TO OUR COLLECTING LOCATION OF CUSTOMER FLEET OR HIRED FLEET VEHICLES WHEN THE CUSTOMER USES THOSE MODULES.

We treat precise geolocation (generally, locating a person within about 1,750 feet under Tennessee law, or about 1,850 feet under California law) as sensitive personal information / sensitive data where those statutes apply. By using the application on a Job, Operators and Drivers consent to that collection and use, because the Service cannot function as a dump-haul Marketplace without it. Additional TIPA and California disclosures are in Sections 20 and 21.

We do not represent that we currently collect background location from every device or OS version. Device operating systems differ. The rule is: we collect location while the app is in use on a Job, and we may collect it in the background if you enable it. You are responsible for granting the OS permission the app requests for the Role you are performing.

3.1 No reasonable expectation of privacy on a Job

Jobsites, plants, quarries, pits, dumpsites, landfills, yards, and in-app Job communications are commercial operating environments, not private spaces. Name, CDL last-four or other identifier we display, vehicle description, plate or unit number, live or recent location, ETA, geofence events, tickets, photos of the load or site, and similar operational data may be visible to the other party to that Job (and to that party’s jobsite, plant, quarry, or receiver as that party directs).

You have no reasonable expectation of privacy in that operational data as against Pro Hauls or the other party to the Job. Collection and display of that data is how a dump-haul Marketplace and a property-broker file work. This Section does not waive any non-waivable statutory privacy right; it allocates expectation as between commercial Users of a Job. Misuse of Job data by another User is addressed in Section 9.12.

We collect the following categories. A given person will not have every category collected. We collect what the Role, the Job, and the law require.

4.1 Identifiers and profile

Name; preferred name; business name; DBA; title; username; hashed or stored credentials; email; postal address; billing address; telephone and mobile numbers; Account ID; customer or operator number we assign; IP address; device identifiers; cookie identifiers; signature (wet-ink image, typed, or captured in-app); profile photo.

4.2 Commercial, fleet, and Marketplace information

Role (Customer, Operator, Driver, Non-Asset Broker, Hired Fleet, Authorized Account User); USDOT number; MC/MX/FF number; operating-authority status; safety rating and SMS (or successor) scores we obtain from public FMCSA sources or vendors; insurance certificates, coverages, additional-insured status, and producer contacts; vehicle class (including tri-axle and other dump configurations); license plate; VIN; unit number; equipment type; number of trucks; material types you haul or tender; Job history on the Platform; completed-jobs data; ratings, complaints, and “bad experience” reports (collected for Pro Hauls’s internal use as stated in the Terms); factoring or assignment notices; Order Form commercial terms.

4.3 Government identifiers and Driver credentials (sensitive)

CDL Number (this identifies the Driver as a person, not the vehicle); CDL class, endorsements, restrictions, issue and expiration dates; medical-examiner certificate / DOT medical card status; state of licensure; images or scans of a CDL, medical card, or other credential you upload; Social Security number, EIN, or ITIN if you provide it for tax reporting, 1099, W-9, KYC, OFAC, or payment onboarding (we do not claim to “own” your SSN; we collect and use it only as stated); other government ID you choose to upload.

4.4 Precise geolocation, GPS, telematics, and Device Data (sensitive)

GPS coordinates, heading, speed, altitude, timestamps; geofence entry and exit at origin, plant, quarry, pit, jobsite, dumpsite, landfill, or yard; ETAs we compute; dwell / wait / detention time; route traces while on a Job; ELD or telematics feeds you or a vendor connect; device motion or diagnostic data the OS or a connected device supplies; approximate location from IP. See Section 3.

4.5 Photographs, video stills, and jobsite media

Photos of scale tickets, load tickets, dump tickets, bills of lading, manifests; photos of the load, dump body, tailgate, material, jobsite, plant, quarry, or dumpsite; in-cab or site photos you upload as proof of performance, contamination, leftover load, damage, or exception; screenshots reasonably uploaded to document a single Job. Consent, User warranty, and indemnity for capture and upload are in Section 4.14. We do not operate a biometric identification system on these images (see Section 13).

4.6 Scale tickets, load tickets, dump tickets, and transcribed records

Ticket images you upload; data elements on a ticket (ticket number, net/gross/tare, tons or yards, material, time, vehicle, customer job number, plant or dumpsite identity); Platform-created tickets generated in optional Ticketing software; transcribed / structured ticket records created by optional Transcription; quantity used to calculate Marketplace Rates, invoices, and Operator Compensation. Rate Engine estimates are not a certified scale weight.

4.7 Jobsite, quarry, plant, and dumpsite operational data

Addresses, gate instructions, dump-room notes, overhead-line and trench warnings, site rules, permitted material types, washout rules, receiver names and numbers, hours, geofences, and other parameters a Customer enters or that we derive. Jobsites are controlled by the Customer, project owner, or a third party, not by Pro Hauls. We still process this information to run the Job.

4.8 Communications (including SMS / RCS)

In-app messages; emails; recorded support calls (with notice where required); SMS, MMS, and RCS content and metadata when you message or are messaged through a Pro Hauls program; push-notification tokens; Job alerts and dispatch notices. Cell-phone numbers collected for SMS/RCS opt-in are used to send the messages you consented to and are not sold. See Sections 4.14 and 12.

4.9 Payment and tax

Bank routing and account (typically tokenized by a processor); ACH authorization; payee name; factoring payee; last four of a card if a processor shares it; payout schedule; invoices; remittance reports; 1099 and backup-withholding data; chargebacks and ACH returns. We do not name a payment processor in this Policy. Full PAN/CVV, if collected at all, is collected by the processor, not stored by Pro Hauls as a card vault.

4.10 Usage Data and technical data

Log files; pages and screens viewed; clickstream; app crashes; feature use; referral URLs; browser and OS; mobile carrier; language; time zone; advertising identifiers if a website analytics SDK collects them (we do not use them for cross-context behavioral advertising as a default — see Section 7). This is “Usage Data” under the Terms and Platform Data, which Pro Hauls owns (Section 8).

4.11 Inferences, scores, and Rate Engine inputs/outputs

Reliability or performance signals; no-show or late patterns; dwell-time distributions; lane and material demand; inferred vehicle-class fit; fraud or collusion flags; Marketplace Rates, Customer Price, Operator Compensation, Platform Spread, and other Rate Engine outputs. These are Platform Data and Pro Hauls’s property (Section 8).

4.12 Sensitive personal information — summary

Where CCPA/CPRA or TIPA terminology applies, the sensitive categories we may collect are: (1) government identifiers (CDL, and SSN/ITIN if provided for tax or KYC); (2) Account log-in with a credential; (3) precise geolocation; (4) contents of SMS/RCS/email when we are a party to the communication. We do not collect biometric identifiers for identification on our servers; we do not seek racial origin, religious belief, health diagnosis, sexual orientation, union membership, genetic data, or neural data as a business practice. Insurance and MVR data may reveal driving or medical-certification status; we use that for eligibility and safety, not to infer unrelated characteristics.

4.13 Information we do not treat as “sold personal information”

De-identified and aggregated operational data, Marketplace Rates as Pro Hauls’s pricing product, and compilation/database rights are Platform Data Pro Hauls owns and are not a “sale of your personal information.” See Sections 7 and 8.

4.14 Recordings, photographs, and jobsite media — consent and User warranty

You consent to Pro Hauls recording support telephone calls (with notice where Applicable Law requires notice), storing in-app chat, storing SMS, MMS, and RCS content and metadata of messages we send or receive in connection with the Services, and collecting photographs and video stills of loads, tickets, equipment, dump bodies, plants, quarries, jobsites, and dumpsites, for billing, claims, safety, quality, fraud prevention, 371 files, Platform records, and the Rate Engine.

If you photograph or record a jobsite, plant, quarry, dumpsite, vehicle, load, or other person in connection with a Job or the Services, you warrant that you have the right to capture that image or recording (including of other people who appear in it) under Applicable Law and site rules, and that uploading it does not infringe privacy, publicity, or property rights. You shall defend, indemnify, and hold harmless the Pro Hauls Indemnified Parties from claims arising from your capture or upload. Pro Hauls may use those images as Platform Data and Platform records under Terms Section 13.12 and under the ownership, assignment, and license terms in Section 8.

Do not photograph children as the subject of a Job photo. A jobsite may have minors present; your photos shall not target them. See Section 14.

We collect information from:

• You and your Authorized Account Users (registration, Jobs, tickets, photos, messages, device permissions);
• Other Users on a Job (Customer sees Operator/Driver/vehicle/ETA; Operator sees jobsite and Customer operational details; ratings and complaints);
• Devices and the Platform itself (GPS, logs, geofences, Rate Engine, ticketing and transcription modules);
• Service providers and vendors (identity, insurance-certificate processing, MVR/CDL verification, SMS/RCS gateways, cloud hosting, mapping, analytics, payment processing, fraud, OFAC screening);
• Public and regulatory sources (FMCSA SAFER, L&I, SMS/CSA or successor systems, Secretary of State, OFAC SDN and similar lists, public court or news sources we may use for fraud or sanctions);
• Insurers, producers, and certificate vendors;
• Your employer or the User that added you to an Account;
• Communications you send us at support@prohauls.co, 1-800-4PROHAUL (1-800-477-6428), or in-app.

We use information to:

1. Create and administer Accounts; authenticate Users; maintain credentials; enforce dual-control on payment-instruction changes.

2. Operate the dump-truck / tri-axle Marketplace and Private Fleet tools — post and display Jobs, match capacity, dispatch, geofence plants/quarries/jobsites/dumpsites, calculate wait/detention against dump free time, and complete Jobs.

3. Determine, quote, update, display, and defend Marketplace Rates through the proprietary Rate Engine (software, data, rules, and algorithms, including artificial intelligence and machine-learning models). The Rate Engine may consider demand and supply; geography and lane; vehicle class (including tri-axle); material type and quantity; distance; time of day, week, and season; weather; fuel; site conditions; User performance or reliability signals; regulatory or prevailing-wage constraints; ticketed tons/yards; GPS dwell; and other factors Pro Hauls deems relevant. Users do not set Marketplace Rates.

4. Train, evaluate, and improve the Rate Engine and dispatch models on an internal basis using User Data, Device Data, Usage Data, tickets, and completed-jobs data, including in identified form while a Job is live and in aggregated or de-identified form thereafter. We do not use Platform data to train a publicly available generative AI model, and we do not authorize Users to do so. Internal Rate Engine training is expressly permitted by the Terms (Sections 3.2, 3.3, 3.7, and 4.2(m)).

5. Broker and document Marketplace transportation as a property broker, including invoices, Operator Compensation, Platform Spread, and 49 C.F.R. Part 371 transaction records (Section 17).

6. Pay and collect; detect chargebacks, mule accounts, factoring fraud, and account takeover; set off amounts as the Terms allow.

7. Eligibility, safety, and compliance — CDL Number, license status, insurance, authority, MVR/background proof, medical-card status, OFAC/sanctions, and commercially reasonable eligibility checks. Those checks are not a warranty of fitness or safety and do not create employment.

8. Create, store, and rely on Platform records as evidence (GPS, timestamps, photographs, tickets, in-app acceptances, Rate Engine displays, invoices, remittance reports, completed-jobs data) as a rebuttable presumption under the Terms.

9. Customer and Operator support; investigate disputes, contamination, leftover load, illegal dumping allegations, overweight, and site incidents. Pro Hauls is not the generator, site owner, or motor carrier.

10. Security, fraud, scrape prevention, and abuse — including enforcing the prohibition on harvesting Job listings, Operator or Customer information, Marketplace Rates, or completed-jobs data, and on using Platform data to feed a competing load board or public AI model.

11. Communications — operational SMS/RCS/email/push/calls as a condition of the Platform; marketing only with separate consent that is not a condition of the Account (Section 12).

12. Improve the Platform, develop features, compile analytics, and create aggregated or de-identified insights that Pro Hauls may use, license, or commercialize (Section 8).

13. Legal, insurance, tax, audit, and defense — including producing records in litigation, arbitration, FMCSA or State audits, and insurance claims.

14. Corporate transactions — due diligence and transfer in a merger, financing, or sale of assets.

15. Any compatible purpose disclosed to you at collection, or with your additional consent, or as Applicable Law allows.

We may de-identify personal information and use de-identified information for any lawful purpose, including licensing operational analytics. We will not attempt to re-identify de-identified information except to test our de-identification, to comply with law, or as otherwise permitted. See Section 7.1.

6.1 Automated decisions; Rate Engine is commercial B2B pricing

Marketplace Rates, matching, ETAs, fraud flags, reliability signals, and similar outputs may be produced in whole or in part by automated systems, including artificial intelligence and machine-learning models (the Rate Engine and related dispatch models). This is commercial B2B pricing and dispatch for a property-broker Marketplace. It is not consumer credit, not an FCRA “credit score” of a natural person in a personal context, and not an employment or hiring decision by Pro Hauls.

Where a consumer privacy statute gives a right to opt out of profiling in furtherance of decisions that produce legal or similarly significant effects, that right — when it actually applies to you as a “consumer” under that statute — does not require Pro Hauls to provide the Marketplace Service without the Rate Engine. Your sole and exclusive remedy for dissatisfaction with automated Marketplace Rates or matching is to decline the applicable Job and/or stop using the Marketplace, consistent with Terms Section 2.8.8. We may still use automated systems for security, fraud, OFAC screening, and 371 recordkeeping. Additional TIPA language is in Section 21.4.

Pro Hauls does not sell personal information for money. We do not exchange your name, CDL Number, GPS trace, phone number, or tickets with a data broker or advertiser for monetary consideration.

We use and may license aggregated and de-identified operational data (cycle times, lane and material indices, dump-market analytics, Rate Engine features that no longer identify a person). That licensing is a commercialization of Pro Hauls’s insights and compilation, not a sale of your personal information.

We share personal information with service providers and with other Users as needed to complete Jobs — for example, a Customer sees Driver name, vehicle, location, and ETA; an Operator sees the jobsite and dumpsite. That is a product disclosure, not a sale.

We do not share personal information for cross-context behavioral advertising as a default. We do not run third-party ad networks against Job GPS or CDL data. If that default changes, we will update this Policy and offer any legally required opt-out before the new practice applies.

SMS/RCS opt-in data is not sold. See Section 9 for the full sharing list and Section 21 for TIPA’s monetary-consideration definition of “sale.”

7.1 Industry reports and licensed insights

We may publish, license, or otherwise commercialize aggregated, de-identified market, lane, material, vehicle-class, cycle-time, dwell, and rate insights (including indices, research notes, and dump-market analytics). Those products are Pro Hauls’s property under Section 8. Once information is de-identified, we will not re-identify it except as Applicable Law allows to test de-identification, to comply with law, or to investigate security. That licensing is a commercialization of Pro Hauls’s insights and compilation, not a sale of your personal information for money.

PRO HAULS OWNS THE DATA.

As between you and Pro Hauls, Pro Hauls owns all Platform Data. This Section is the centerpiece of this Policy. Read it with Terms Sections 3.1 (Platform ownership), 3.2 (Usage Data), 3.3 (User Content assignment), 3.4 (Feedback), 3.7 (Device Data), 4.2 (no scrape / no public-AI training), 10.2 (privacy), and 13.12 (Platform records as evidence). The Privacy Policy controls over the Terms if they conflict with respect to personal information; on ownership and assignment of Platform Data and User Content, this Section and Terms Section 3 are intended to say the same thing.

8.1 What “Platform Data” means — Pro Hauls owns it

As between you and Pro Hauls, Pro Hauls and its licensors own all right, title, and interest in and to all “Platform Data,” including without limitation:

• (a)The Platform and software. The websites, mobile applications, APIs, documentation, user interface, trademarks (including Pro Hauls), look and feel, and all software.
• (b)Account and profile data submitted to the Platform. Name, business name, contact points, Role, credentials (as stored), insurance and authority files as maintained on the Platform, CDL Number and related eligibility file as maintained on the Platform, and other Account data you or your Authorized Account Users submit.
• (c)Job, ticket, GPS/Device Data, photos, and communications stored on the Platform. Job files; scale/load/dump tickets and images; GPS, telematics, and other Device Data as ingested and stored; photographs and video stills; in-app chat; SMS/MMS/RCS content and metadata of messages we send or receive in connection with the Services; and similar operational records.
• (d)Usage Data. Information about use of the Platform, as defined in the Terms. Pro Hauls owns Usage Data and may use it for any lawful purpose, including operating and improving the Platform, developing products, training the Rate Engine internally, and creating aggregated or anonymized insights.
• (e)The Rate Engine. Models, weights, parameters, feature stores, training sets Pro Hauls compiles, rules, source code, object code, prompts, evaluation harnesses, inputs used to produce rates, outputs (including Marketplace Rates, Customer Price, Operator Compensation, accessorial calculations, quotes, scores, and insights), and all improvements. A displayed rate is Pro Hauls’s pricing product, not yours.
• (f)Aggregated and de-identified data. Data that does not reasonably identify you or any natural person, including lane-level, material-level, vehicle-class, cycle-time, and dump-market analytics. Pro Hauls may use, license, sell, or otherwise commercialize aggregated and de-identified data. That commercialization is not a sale of personal information for money.
• (g)Derived insights and scores. Reliability signals, fraud flags, inferred demand, rankings, and other derivatives Pro Hauls creates.
• (h)Compilations, databases, schemas, and logs. The selection, arrangement, schema, index, and compilation of the Platform database as a whole; system logs; access logs; Rate Engine decision logs; Marketplace Rates as recorded; Platform-created tickets and transcribed/structured ticket records. You have no right to a copy of the compilation, to scrape it, or to treat the Marketplace as your dataset.
• (i)Feedback. Suggestions and enhancement requests are assigned to Pro Hauls under the Terms.
• (j)Processed Device Data and Platform records. Once location, telematics, GPS, timestamps, photographs, and similar Device Data are ingested, mapped, geofenced, ETA-calculated, or compiled into a Job file, that processed operational record is Platform Data Pro Hauls owns. Platform records are evidence under Terms Section 13.12.

Reservation. Pro Hauls reserves all rights not expressly granted. A limited access right to use the Platform (Terms Section 2.2) is not a data-ownership grant to you.

8.2 Assignment — you assign User Content and data to Pro Hauls

“User Content” (also called “User Data” in the Terms) means data, content, and materials that you or your Authorized Account Users submit to, generate on, or cause to be processed through the Platform — including Account and profile submissions, Job parameters, tickets and ticket images, photographs, chat and SMS content you send through a Pro Hauls program, Device Data generated on a Job, and similar materials.

By creating an Account, clicking to accept, signing an Order Form, or accessing or using the Platform, User hereby assigns to Pro Hauls LLC all right, title, and interest in and to User Content and data submitted to, generated on, or processed through the Platform, to the maximum extent permitted by Applicable Law. That assignment includes the right to use, reproduce, modify, create derivative works from, commercialize, disclose, retain, license, and otherwise exploit that data as Platform Data, including for the Rate Engine, Marketplace pricing, billing, 371 files, fraud prevention, product improvement, and aggregated or de-identified commercialization.

You do not acquire ownership of Pro Hauls property by uploading something, by appearing in a Job file, or by being assigned a rate. You do not own Marketplace Rates, the Rate Engine, Usage Data, processed Device Data, Platform-created tickets, compilations, or other Users’ data.

8.3 Fallback exclusive license (where assignment is not permitted)

Where Applicable Law does not permit assignment of a particular item of User Content or data, User instead grants Pro Hauls an exclusive, perpetual, irrevocable, worldwide, royalty-free, fully paid, transferable, sublicensable (through multiple tiers) license that is the economic equivalent of ownership, including the rights to use, host, store, reproduce, copy, distribute, publicly display, publicly perform, adapt, translate, modify, create derivative works from, commercialize, disclose, and retain that item, and to exercise all other rights a copyright owner or database owner could exercise, for any lawful purpose consistent with this Policy and the Terms (including internal Rate Engine training and aggregated/de-identified products).

That fallback license survives termination of the Account and of the Terms to the extent Pro Hauls has a continuing operational, legal, Rate Engine, tax, audit, or defense need. It is the license contemplated by Terms Section 3.3 where assignment does not run.

Internal vs. public AI. Assignment and the fallback license authorize Pro Hauls’s internal training and improvement of the Rate Engine and Platform. They do not authorize Pro Hauls to feed your identified personal information into a third party’s publicly available generative-AI foundation model as that party’s training corpus. They do not authorize you to train a public model or a competing load board on Platform Data (Terms Section 4.2(m)).

8.4 Narrow license-back to User

Pro Hauls grants User a limited, non-exclusive, non-transferable, revocable license to access and export their own invoices, completed-jobs history, and tax records as displayed in the Account, solely for User’s own internal business and tax compliance.

That license-back does not give User ownership of Platform Data, Rate Engine outputs, Marketplace Rates, other Users’ data, compilations, databases, schemas, logs, Feedback, Usage Data, or GPS/Device Data files as structured, processed, or compiled by Pro Hauls. It does not authorize scraping, bulk export of the Marketplace, republication, or competitive use. Pro Hauls may revoke the license-back for material breach, Account closure for cause, or as needed to protect the Platform, without affecting Pro Hauls’s ownership of Platform Data.

8.5 What we do NOT claim to “own” (compliance carve-outs)

So the ownership claim stays honest and legally compliant, Pro Hauls does not claim to “own” the following:

• Government-issued credentials as issued. We do not claim title to a government-issued credential itself (for example, the physical or digital CDL card as issued by the State). We do own our copy and record of the CDL Number and the related eligibility, verification, and Job file maintained on the Platform. We do not claim to “own your SSN”; we collect and use SSN/ITIN only as stated (tax, 1099, KYC, OFAC, payment onboarding).
• Non-waivable statutory privacy rights. We do not waive, and you do not waive by this Policy, non-waivable consumer privacy rights under TIPA, CCPA/CPRA, FCRA, DPPA, or similar statutes where they actually apply. Those rights, when they apply, operate as a limit on a particular processing or as a deletion/access right — not as a transfer of the Rate Engine, the database, or Platform Data ownership to you.
• Third-party trademarks that appear by accident. We do not claim ownership of a third party’s trademark that appears in a photo by accident (for example, a logo on a building or truck in a wide jobsite shot). We still own the Platform copy of the photo as Platform Data.
• Pro Hauls employee / HR data. Employment and HR data of Pro Hauls’s own employees and job applicants (in their HR capacity) is out of scope of this Policy’s User-facing ownership terms; those individuals receive any legally required employment notice separately.

8.6 Personal information vs commercial ownership

Owning Platform Data means Pro Hauls controls and may use, retain, assign further, license, and commercialize it as stated in this Policy and the Terms. It does not mean Pro Hauls “owns your body,” owns you as a person, or can ignore a deletion, access, or correction right that Applicable Law requires when that law actually applies to you.

Deletion rights, when they apply, do not unwind de-identified Rate Engine artifacts, weights, or training sets; 49 C.F.R. Part 371 broker records; invoices, remittances, and records needed for tax, audit, insurance, or legal holds; Marketplace Rates already produced; compilation and database rights; or Usage Data that is not “your” personal information to delete. See Sections 10 and 19.

8.7 Other Users on a Job; no privacy expectation

Other Users on a Job still see operational data as Section 9.1 describes. You have no reasonable expectation of privacy in operational Job data as against Pro Hauls or the other party to the Job (Section 3.1). Ownership of Platform Data by Pro Hauls does not prevent product disclosures needed to run a dump-haul Marketplace.

8.8 Ownership is not a “sale” of personal information for money

Pro Hauls does not sell personal information for money as a default (Section 7). Ownership ≠ selling personal information. Aggregated and de-identified commercialization of Pro Hauls’s insights and compilations remains permitted and is not a sale of your personal information for money.

8.9 Other Users; no exfiltration

You may use another User’s location, ETA, name, vehicle, jobsite, or ticket information only to perform the Job for which it was disclosed. You shall not scrape, harvest, copy, resell, republish, or exfiltrate another User’s personal information or Pro Hauls’s Marketplace Rates, listings, or compilations. Doing so is a material breach of the Terms and of this Policy and may be theft of trade secrets or a violation of the Computer Fraud and Abuse Act, state computer-crime statutes, and privacy law. We may suspend Accounts, seek injunctive and other equitable relief in the Tennessee courts specified in Terms Sections 13.1, 13.11, and 13.15(d) (including without posting a bond to the extent permitted), and notify other Users or authorities. See Section 27.

8.10 Confidentiality of the Rate Engine

The Rate Engine, Marketplace Rates, feature stores, weights, parameters, prompts, evaluation harnesses, decision logs, and related pricing artifacts are Pro Hauls Confidential Information and trade secrets (Terms Sections 3.1, 2.8, and 10.1). Access to displayed rates is a limited license to use the Platform to evaluate or perform a Job, not a data dump you own. You shall not probe, scrape, harvest, spider, reverse engineer, benchmark for a competing product, or systematically record Marketplace Rates or Rate Engine outputs. Doing so is a material breach and may be misappropriation. This Section 8.10 is in addition to Section 8.9 and Terms Section 4.2.

Default stance: Pro Hauls does not sell personal information for money. We use and may license aggregated and de-identified operational data. We share personal information with service providers and with other Users as needed to complete Jobs. We do not share personal information for cross-context behavioral advertising as a default practice. If that default ever changes, we will update this Policy and provide any opt-out required by Applicable Law before we start.

9.1 Other Users — what they see on a Job

The Marketplace cannot run as a black box. On an accepted or active Job (and as needed to offer a Job):

• The Customer (and its jobsite, plant, quarry, or receiver as the Customer directs) may see the Operator’s and Driver’s name or handle, CDL last-four or similar identifier we choose to display, vehicle description, plate or unit number, phone number for dispatch, live or recent GPS location, ETA, geofence events, ticket status, photos, and performance notes for that Job.
• The Operator and Driver may see the Customer name, jobsite and dumpsite addresses, gate and dump instructions, material type, contact numbers, and other operational details needed to haul and dump lawfully.
• A Non-Asset Broker or Hired Fleet Operator may see what that Role requires, subject to the Terms’ no-hidden-brokerage rules.

This sharing is a product-or-service disclosure, not a sale. Delivery-status sharing tools, if the Customer enables them, may share GPS and names with a Customer-designated recipient; the Customer represents it has permission.

As stated in Section 3.1, you have no reasonable expectation of privacy in operational Job data as against Pro Hauls or the other party to that Job. Name, CDL last-four or as displayed, vehicle, location, ETA, tickets, and photos of the load or site are commercial Job data.

9.2 Service providers (processors)

We share information with vendors who host, message, map, verify identity or CDL/MVR, process certificates of insurance, process payments, transcribe tickets, screen OFAC, analyze fraud, provide customer support tools, or similar. They may use the information only to serve Pro Hauls, except that a payment processor or SMS aggregator also acts under its own terms for the rails it operates. We do not name those processors here.

9.3 Affiliates; professional advisors

We may share with Affiliates under common control, and with lawyers, insurers, accountants, and auditors under confidentiality.

9.4 Insurers, certificate vendors, and additional-insured parties

Insurance certificates, additional-insured status, and claim facts may be shared with Customers, insurers, and certificate processors as needed for a Job or a claim.

9.5 FMCSA, State agencies, law enforcement, legal process, and defense of Pro Hauls

We may disclose information to courts, regulators (including FMCSA and State DOT), law enforcement, sureties, insurers, auditors, and opposing counsel, with or without notice to you where Applicable Law allows (including gag orders, delayed-notice process, and national-security process), when we in good faith believe disclosure is appropriate to operate the Platform, collect amounts due, protect safety, property, or rights, or defend Pro Hauls, its Affiliates, or other Users. We may also disclose when we believe it is required by law, legal process, FMCSA or State audit, a warrant, subpoena, civil investigative demand, or similar compulsory process. Location data will be shared with DOT/FMCSA or law enforcement when we reasonably believe we must. We have no contractual duty to fight a subpoena or to notify you if notice is forbidden or if we reasonably conclude notice would risk the investigation, a Job, or our defense.

9.6 OFAC, fraud, sanctions, and security

We may share information with screening vendors, financial institutions, other platforms (to the extent lawful, for fraud rings), and authorities to freeze Accounts, withhold funds, refuse Jobs, or report suspected fraud, mule activity, double brokerage, identity theft, or sanctions hits, as the Terms allow.

9.7 FCRA consumer-reporting agencies and MVR vendors

If we obtain or furnish information in a manner that implicates the Fair Credit Reporting Act, we share with those bureaus or vendors as FCRA permits. See Section 15.

9.8 Corporate transactions; sale of the business

A successor, Affiliate, financing source, or buyer in a merger, equity sale, asset sale, reorganization, or financing — and that party’s advisors — may receive all information we hold. This Policy continues as to that information unless the recipient provides a replacement notice. We intend that transfer as a business transfer, not a “sale of personal information” for monetary consideration under CCPA, TIPA, or similar statutes. We will disclose it as a business transfer. We will require the recipient to honor this Policy or to provide legally required notice.

9.9 With your direction or additional consent

If you connect a third-party TMS, accounting system, scale, or ELD, or if you ask us to send a ticket or status to a designated email, we share as you direct. That recipient’s policy governs its use.

9.10 Aggregated / de-identified licensing

We may license or otherwise commercially exploit aggregated or de-identified operational data, including dump-cycle, lane, material, and rate-index products that do not reasonably identify a natural person. That is not a sale of personal information for money.

9.11 What we do not do by default

• We do not sell personal information for monetary consideration (TIPA “sale”).
• We do not sell or share personal information for cross-context behavioral advertising (CCPA “sale” / “share”) as a default. Website analytics cookies are described in Section 22; we do not run a third-party advertising network against your Job GPS or CDL.
• We do not sell SMS/RCS opt-in data.
• We do not disclose your information to a competing Marketplace because a competitor asked.

9.12 Other Users’ misuse of Job contact and location data

If a Customer, Operator, Driver, or other User misuses location, telephone numbers, names, or other information obtained on a Job — including spam, stalking, competing dispatch, harvesting a contact list, or off-platform solicitation in breach of the Terms — that is the misuser’s liability. Pro Hauls may deactivate or restrict Accounts under the Terms. Pro Hauls is not liable for that misuse beyond Terms Section 8. Report abuse to support@prohauls.co. We have no duty to monitor every User communication.

We retain information as follows. When two periods apply, the longer period controls.

Account closure is not a deletion of broker records, invoices, tickets, or de-identified model improvements. Pro Hauls has no duty to preserve records beyond ordinary retention and Applicable Law (Terms Section 13.12), and no duty to preserve them for your off-platform lawsuit except a valid legal hold.

If you request deletion and an exception applies (open Job, unpaid invoice, 371 file, FCRA, legal hold, security), we will delete or de-identify what we can and retain the rest.

10.1 No duty to retain for User’s convenience

We may delete, archive, or overwrite operational data on our schedule, except where Applicable Law requires retention (including 49 C.F.R. Part 371, tax, insurance, and legal holds). You should export and keep your own records. Pro Hauls is not a system of record for your tax file, your FMCSA motor-carrier file, or your internal safety program, except the 371 brokerage-transaction file as to Pro Hauls as broker. We have no duty to produce a custom archive for your off-platform lawsuit except a valid legal hold or compulsory process. Account closure is not a demand that we keep data for your convenience, and it is not a demand that we erase broker records, invoices, or de-identified Rate Engine artifacts.

We use commercially reasonable administrative, technical, and physical safeguards designed to protect information in our possession (for example, access control, encryption in transit where appropriate, and vendor contracts). No method of transmission or storage is 100% secure. Internet transmissions may be intercepted before they reach us or after they leave us. You are responsible for credentials, for notifying us of unauthorized access, and for dual-control of bank-instruction changes, as the Terms require.

11.1 No extra privacy warranty

This Policy is a notice and a commercial allocation of data rights. It is not a warranty of security, confidentiality, uninterrupted privacy, or error-free processing. We do not guarantee against: (a) a security incident; (b) another User’s acts or omissions; (c) device, operating-system, GPS, mapping, or carrier failure; (d) interception of internet or wireless transmissions; or (e) public records and FMCSA databases that third parties already publish. You use the Platform at your own risk. Terms Section 7 (disclaimer of warranties) and Section 8 (limitation of liability) apply to privacy, security, and data claims to the maximum extent permitted by Applicable Law. This Policy does not create a security SLA, an extra indemnity running from Pro Hauls, or extra damages.

11.2 Security incidents; no extra contractual notice

If Applicable Law requires notice of a security incident or breach of personal information (including, if it applies, the Tennessee breach-notice statute, Tenn. Code Ann. § 47-18-2107 or successor), we will notify as that law requires. We have no contractual duty to notify faster, more broadly, or in more detail than Applicable Law requires. We do not promise liquidated damages, automatic credit monitoring, identity-theft insurance, or a particular forensic vendor, unless we choose in writing to offer them in a particular incident. Notice is not an admission of fault.

You shall cooperate reasonably in any incident investigation and keep Account credentials secure as the Terms require. Pro Hauls is not liable for incidents caused by you, your Authorized Account Users, other Users, or processors, beyond Terms Section 8.

This Section aligns with Terms Section 3.5. It is a privacy disclosure and a consent record.

BY CREATING AN ACCOUNT OR PROVIDING A TELEPHONE NUMBER, EMAIL ADDRESS, OR OTHER CONTACT POINT, YOU EXPRESSLY CONSENT TO RECEIVE COMMUNICATIONS FROM PRO HAULS, ITS AFFILIATES, AND THEIR SERVICE PROVIDERS RELATED TO THE SERVICES. THOSE COMMUNICATIONS INCLUDE CALLS, SMS, MMS, RCS, IN-APP MESSAGES, PUSH NOTIFICATIONS, AND EMAIL, AND MAY BE SENT USING AN AUTOMATIC TELEPHONE DIALING SYSTEM (ATDS), A PRERECORDED OR ARTIFICIAL VOICE, OR SIMILAR TECHNOLOGY.

OPERATIONAL AND TRANSACTIONAL MESSAGES INCLUDE JOB ALERTS, DISPATCH AND STATUS NOTICES, PAYMENT AND INVOICE NOTICES, SECURITY ALERTS, AND SIMILAR SERVICE MESSAGES. CONSENT TO OPERATIONAL MESSAGES IS A CONDITION OF USING THE PLATFORM. OPTING OUT OF OPERATIONAL MESSAGES MAY LIMIT OR PREVENT USE OF THE SERVICES.

MARKETING OR PROMOTIONAL MESSAGES ARE SEPARATE. MARKETING CONSENT IS NOT A CONDITION OF CREATING AN ACCOUNT OR OF USING THE PLATFORM. You may opt out of marketing as described in the applicable notices, by emailing support@prohauls.co, or by following instructions in the message.

FOR SMS, MMS, OR RCS, YOU MAY TEXT STOP TO OPT OUT OF A MESSAGE PROGRAM OR HELP FOR HELP. MESSAGE AND DATA RATES MAY APPLY. MESSAGE FREQUENCY VARIES. STOP on a marketing program does not cancel operational Job messages if those are a different program; we may tell you how to manage operational messages. We are not liable for delayed or undelivered messages. Wireless carriers are not liable for delayed or undelivered messages.

You warrant that each number you provide is yours (or that you are authorized to consent for the subscriber). You shall promptly notify Pro Hauls if you change, reassign, or relinquish a number. You shall defend, indemnify, and hold harmless the Pro Hauls Indemnified Parties from TCPA, state mini-TCPA, and similar claims arising from a number that is not yours, from your failure to notify us of a number change, or from communications sent to a number you designated.

SMS/RCS opt-in data is not shared with third parties for their marketing. Service providers who transmit the messages are processors.

Pro Hauls does not collect, store, or use biometric identifiers or biometric information on its servers for the purpose of identifying you. We do not operate a faceprint, fingerprint, voiceprint, retina, or similar matching system.

If your phone, tablet, or computer uses Face ID, Touch ID, fingerprint, or similar device unlock, that template stays on the device under the OS vendor’s control. We may receive only a pass/fail from the OS that you successfully unlocked the device. That is not biometric information stored by Pro Hauls.

Photos of CDLs, tickets, loads, and jobsites are not collected to extract a biometric identifier. We do not enroll those images in a biometric database.

If we ever offer a voice or biometric feature that would collect a biometric identifier on our servers, we will provide a separate written policy and obtain any consent Illinois BIPA, Texas CUBI, or similar law requires before that collection. Until then, do not interpret Job photos or support call recordings (which are audio records of a conversation, not a voiceprint template) as BIPA biometric collection.

The Platform is a commercial dump-haul and brokerage tool. You must be at least eighteen (18) years old to create an Account or use the Services. No person under eighteen may operate a vehicle in connection with any Job, even if the Account is held by an entity (Terms Introduction and Section C.1.10.1).

We do not knowingly collect personal information from children under 13 (COPPA) or under 18. If we learn we have, we will delete it, except records we must keep by law. Parents: contact support@prohauls.co.

14.1 Minors at jobsites; do not cause us to collect children’s data

You shall not cause Pro Hauls to collect personal information from a child. A jobsite, plant, quarry, dumpsite, or public right-of-way may have minors present. Job photos and video shall not target children as the subject. If a child incidentally appears in a wide shot of a site or load, you still warrant you had the right to capture the image (Section 4.14). We may delete media that appears to depict a child as the subject. This Section does not make Pro Hauls responsible for who is present at a jobsite we do not control.

Invoices, Operator Compensation, ACH credits, and similar money movement are processed by third-party payment processors and banks. We do not name those processors in this Policy. You provide account and routing information (or card information, if we ever enable cards) to the processor or through fields that pass to the processor. Pro Hauls does not operate a card vault. The processor’s privacy notice governs PAN, CVV, and bank-account storage on its rails. We receive tokens, last-four, payee name, confirmation, and failure codes as needed to pay, invoice, set off, and fight chargebacks.

Dual-control on changes to bank routing, beneficiary name, factoring assignment, or ACH payee is described in the Terms. Pro Hauls is not liable for a payment it reasonably believed authentic.

Background and motor-vehicle records as Marketplace eligibility. Under the Terms, Operators must, at Operator’s expense, obtain an MVR and a commercially reasonable criminal-background check on each Driver before the Driver’s first Job (and at intervals the Operator’s safety program requires), using a qualified third party. Those checks are a condition of Marketplace eligibility. They are run by the Operator (or the Operator’s vendor), not by Pro Hauls as an employer. Pro Hauls may require proof and may rely on it without repeating the check.

Pro Hauls may also obtain consumer reports itself. Pro Hauls may verify CDL Numbers, license status, medical certification, and driving records through third parties, and may obtain or review consumer reports (including MVRs and, where used, criminal or identity-theft reports) for a permissible purpose under the Fair Credit Reporting Act, 15 U.S.C. § 1681 et seq. (“FCRA”), including:

• eligibility to access the Marketplace or to be offered a Job as an independent Operator or Driver, not as a Pro Hauls employee;
• fraud, identity, and safety screening;
• a legitimate business need in connection with a business transaction initiated by you.

Authorization. By creating an Account, providing a CDL Number, or dispatching or driving on a Job, you authorize Pro Hauls and its vendors, to the maximum extent permitted by FCRA and state analogs, to obtain, use, and evaluate such consumer reports for those purposes, and you authorize the Operator that engaged you to share proof of Operator-run checks with Pro Hauls. If you are submitting a Driver who is not you, you represent the Driver has authorized the same.

Not employment. Obtaining, reviewing, or relying on a consumer report or MVR is not an offer of employment, a hiring decision, or control of the means of transportation. Adverse Platform action (including deactivation under Terms Section C.1.12) is a platform-access decision.

Adverse-action notices. If Pro Hauls takes adverse action based in whole or in part on a consumer report that Pro Hauls procured, Pro Hauls will provide any notice and copy FCRA requires, including the name of the consumer reporting agency. If the Operator procured the report, the Operator is responsible for any employer or FCRA notice that law places on the Operator.

FCRA data exemption. Information we process as a consumer report, or that is otherwise subject to FCRA, may be exempt from TIPA and from parts of other state privacy laws. A deletion request does not require us to erase a consumer report we must keep or to un-do a legally required adverse-action file.

The federal Driver’s Privacy Protection Act, 18 U.S.C. § 2721 et seq. (“DPPA”), and state motor-vehicle privacy laws restrict disclosure of personal information from state motor-vehicle records.

CDL Number identifies the Driver (the person), not the vehicle. We collect CDL Numbers, license status, endorsements, medical-card information, and, where obtained, MVRs only for permissible purposes, including:

• use in connection with motor-vehicle or Driver safety and theft, and Marketplace eligibility and fraud prevention;
• use in the normal course of business to verify accuracy of personal information submitted to us, or to obtain correct information, for the purpose of preventing fraud, pursuing legal remedies, or recovering on a debt or security interest;
• use with the express consent of the person to whom the information pertains (which you give by submitting the CDL Number and using the Platform);
• use as a property broker documenting a transaction and selecting or displaying an Operator under commercially reasonable eligibility checks;
• any other purpose DPPA or the issuing State expressly permits.

We do not disclose CDL or MVR personal information for marketing lists, and we do not sell it for money. We may share it with verification vendors, with a Customer on a Job to the limited extent needed to confirm the Driver who arrived, with insurers on a claim, and with government authorities as required.

False, expired, suspended, or mismatched CDL information is grounds for immediate suspension and Job cancellation. Collection of a CDL Number does not create employment or a Pro Hauls-issued vehicle identifier.

State DMV records remain subject to the issuing State’s law. We are not the State, and a privacy request to us is not a DMV record request.

As a registered property broker, Pro Hauls must keep a record of each brokerage transaction. Under 49 C.F.R. § 371.3 (and any successor), that file typically includes names and addresses of the consignor and consignee (or the Customer and receiving location as the dump analog), origin and destination, dates, a description of the freight (material type and quantity as tendered), the amount of Pro Hauls’s compensation and the amount paid to the carrying motor carrier, and the identity of the originating motor carrier / Operator.

Those records are Pro Hauls’s broker files. They may contain personal information. We retain them at least three (3) years after the transaction, and longer if a successor rule, tax law, or legal hold requires. A consumer deletion request does not override 49 C.F.R. Part 371. We may produce these files to FMCSA, a State, a court, or an insurer.

Broker records are also Platform records that may be used as evidence under the Terms. GPS, tickets, photos, and Rate Engine displays that substantiate a 371 file are retained with it.

Private Fleet Hauls that are software-only (not Marketplace brokerage) are not 371 broker transactions, but we may still retain analogous operational records for billing, disputes, and product improvement.

Depending on your jurisdiction and on whether you are a “consumer” under a particular statute (many B2B and employment uses are excluded), you may have some of the following rights. We honor legally required rights. We also accept requests at the same inbox even if we conclude a statute does not apply; we may then grant, deny, or partially grant as a matter of policy without conceding coverage.

Available to the extent required (or as we choose to extend):

• Know / access / confirm — whether we process personal information about you, and categories or specific pieces as the statute requires;
• Correct inaccurate personal information we maintain;
• Delete personal information, subject to the exceptions below;
• Portability — a copy in a readily usable format, where required and technically feasible;
• Opt out of sale / sharing / targeted advertising / certain profiling — our default is that we do not sell personal information for money and do not share for cross-context behavioral ads. If you still wish to record an opt-out, email us. We will treat it as an instruction not to start those activities as to you;
• Limit use of sensitive personal information (California) — we use sensitive PI to provide the Service (including required Job GPS and CDL eligibility), for security, and for other permitted purposes. We do not use it to infer unrelated characteristics for advertising;
• Appeal a denied request (TIPA and some other states) — Section 21;
• Non-discrimination for exercising a right the law actually gives you.

19.1 How to request; identity verification; fees; timing; authorized agents

Email support@prohauls.co with the subject line “Privacy Request,” or write Pro Hauls LLC, Attn: Privacy, 302 Orlando Ave, Nashville, TN 37209, or call 1-800-4PROHAUL (1-800-477-6428). Tell us which right you assert, the email and Account at issue, and enough detail to locate you.

Identity verification. We may require a signed declaration under penalty of perjury, a match to Account data, a government-identifier last-four, a callback to a number on file, a notarized authorization, or other reasonable verification. We may deny unverified requests and requests that we cannot reasonably match to a record we maintain.

Excessive or unfounded requests. We may charge a reasonable fee or refuse requests that are manifestly unfounded, excessive, repetitive, or harassing, as TIPA, CCPA, and similar statutes allow.

Timing. We will respond within the time Applicable Law requires — commonly forty-five (45) days, with a lawful extension of another forty-five (45) days when reasonably necessary, with notice of the extension. TIPA appeal timing is in Section 21.5.

Authorized agents. An authorized agent must present written permission signed by you, or a power of attorney. We may still verify with you directly. We may deny an agent who cannot document authority.

19.2 Exceptions — including records we need not delete

We may deny or limit a request when:

• we cannot verify you;
• the information is not about you as a consumer (B2B / employment / contractor-of-a-User);
• we must keep it under 49 C.F.R. Part 371, tax, accounting, insurance, or a legal hold;
• it is subject to FCRA or DPPA limitations;
• it is Usage Data, de-identified or aggregated data, Rate Engine artifacts, or compilation rights that are not “your” personal information to delete;
• deletion would break an open Job, unpaid invoice, dispute, or security investigation;
• another User also needs the information for a Job, claim, or dispute;
• another exception in CCPA, TIPA, or other Applicable Law applies (complete a transaction, detect security incidents, debug, free speech, internal uses reasonably aligned with your relationship with us, or comply with law).

We need not honor deletion of: 49 C.F.R. Part 371 broker records; tax, invoice, remittance, and accounting records; security, fraud, OFAC, and abuse files; de-identified Rate Engine artifacts, weights, and training sets; Usage Data and compilation rights; information another User also needs for a Job, claim, or dispute; Platform records that are evidence under Terms Section 13.12; or consumer reports we must keep under FCRA.

You may not use a privacy request to obtain another User’s personal information, Marketplace Rates as a dataset, or the Rate Engine. Statutory deletion and access rights, when they apply, operate as a limit on a particular processing — not as a transfer of the Rate Engine or the database to you, and not as a waiver of Terms Sections 8, 13.10, or 13.15.

This Section is a notice at collection under the California Consumer Privacy Act as amended by the California Privacy Rights Act (collectively, “CCPA”), Cal. Civ. Code § 1798.100 et seq., and related regulations. It applies to California residents who are “consumers” under CCPA. CCPA covers some business-to-business and employment information; TIPA generally does not. We provide this notice to California residents at or before collection, including by posting this Policy at https://www.prohauls.co/privacy-policy and in the apps.

20.1 Categories collected, purposes, sale/share, retention

In the preceding 12 months we have collected, or we will collect, the categories in Section 4. In CCPA category language, that includes:

Sources: Section 5. Purposes: Section 6 (including Rate Engine). Categories of recipients: Section 9 (other Users on a Job; service providers; affiliates; insurers; authorities; corporate-transaction parties).

We do not sell personal information. We do not share personal information for cross-context behavioral advertising. We have not sold or shared (as CCPA defines those terms) personal information in the 12 months before this Effective Date. We do not have actual knowledge of selling or sharing personal information of consumers under 16. If website analytics are ever deemed a “sale” or “share” in a particular configuration, the categories would be identifiers and internet activity disclosed to analytics providers, and you may opt out by emailing support@prohauls.co and, if you are a “consumer,” by using a recognized opt-out preference signal (such as Global Privacy Control) to the extent legally required (see Section 20.3). Our default is not to run that configuration against Job GPS or CDL data.

20.2 Sensitive personal information

We collect precise geolocation, government identifiers (CDL, and SSN/ITIN if provided), and Account log-in. We use sensitive personal information to provide the Services a reasonable consumer would expect (dispatch, Job tracking, eligibility, security, payroll/1099, fraud), and for other CCPA-permitted purposes (security incidents, resisting illegal acts, short-term transient use, performing services on behalf of the business, verifying quality). We do not use or disclose sensitive personal information to infer characteristics for advertising. A separate “Limit the Use of My Sensitive Personal Information” link is not required while that is true. Precise geolocation on a Job is required for Operators (Section 3); limiting it is incompatible with performing the Job.

20.3 Your California rights

California consumers may request: (1) to know categories and specific pieces collected, sources, purposes, and categories of third parties; (2) deletion; (3) correction; (4) opt-out of sale/sharing (we do not sell or share; you may still submit an opt-out); (5) to limit use of sensitive PI beyond permitted purposes (we do not so use it); (6) non-discrimination; (7) access via an authorized agent. Submit as in Section 19. We will verify and respond as CCPA requires.

Shine the Light (Cal. Civ. Code § 1798.83). We do not disclose personal information to third parties for their own direct marketing in a manner that triggers an annual Shine the Light list. If that changes, California residents may email support@prohauls.co with subject “Shine the Light.”

Do Not Track / Global Privacy Control. We do not currently respond to browser “Do Not Track” (DNT) signals. If Applicable Law requires us to honor a universal opt-out preference signal (such as Global Privacy Control) for “sale” or targeted / cross-context behavioral advertising, we will honor it for “consumers” as that law defines them. B2B Account Users acting in a commercial or employment context are not “consumers” under TIPA and several other state statutes. Default: we do not sell personal information for money and we do not engage in cross-context behavioral advertising to consumers. An opt-out is an instruction not to start those activities as to you; it is not a right to use the Marketplace without GPS, CDL eligibility, or the Rate Engine.

20.4 Notice to California Operators and Drivers

If you haul a Job in California, we still collect GPS, CDL, and tickets as described. Independent-contractor classification is governed by the Terms (including Schedule C). This Policy does not claim an AB 5 exemption or Proposition 22 coverage.

The Tennessee Information Protection Act, Tenn. Code Ann. § 47-18-3201 et seq. (“TIPA”), took effect July 1, 2025. This Section is provided whether or not TIPA currently applies to Pro Hauls or to you.

21.1 Applicability; B2B, employee, FCRA, DPPA, and broker-record exceptions

TIPA applies to persons that conduct business in Tennessee or produce products or services targeted to Tennessee residents, that exceed $25 million in revenue, and that during a calendar year either (a) control or process personal information of at least 175,000 Tennessee consumers, or (b) control or process personal information of at least 25,000 Tennessee consumers and derive more than 50% of gross revenue from the sale of personal information.

TIPA defines “consumer” as a natural person who is a Tennessee resident acting only in a personal context. It does not include a natural person acting in a commercial or employment context. Many Pro Hauls Users are businesses, and many Drivers and dispatchers act for an Operator or Customer. TIPA also includes data-level exemptions, including information governed by FCRA, the DPPA, GLBA, HIPAA, and similar regimes, and de-identified or aggregate data. Property-broker recordkeeping under federal law is a legal obligation that continues even if a TIPA deletion right would otherwise apply to a consumer.

We do not concede that Pro Hauls currently meets TIPA’s dual threshold, that any particular User is a TIPA “consumer,” or that a particular record is in scope. If TIPA applies, this Policy is intended to satisfy TIPA’s privacy-notice requirements. If it does not apply, this Policy still describes our practices.

TIPA’s “sale” is an exchange of personal information for valuable monetary consideration to a third party, with listed exceptions (processors, product-or-service disclosures, affiliates, public information, M&A). We do not sell personal information for money. Licensing aggregated or de-identified operational data is not a TIPA sale of personal information.

21.2 Categories, purposes, sharing — TIPA notice content

• Categories of personal information processed: Section 4.
• Purposes: Section 6, including Rate Engine operation and internal training.
• Categories shared with third parties: identifiers, commercial/Job data, geolocation, government IDs as needed for eligibility, internet activity with processors, visual/ticket data, inferences as operational signals.
• Categories of third parties: other Users on a Job (Customers, Operators, Drivers, jobsite/plant/dumpsite contacts); service providers (hosting, messaging, mapping, payments, verification, insurance certificates, transcription, fraud/OFAC); professional advisors; insurers; FMCSA and government authorities; corporate-transaction counterparties.
• Sensitive data: TIPA treats as sensitive, among other things, precise geolocation (locating a person within a radius of 1,750 feet), government-quality identifiers when they reveal listed attributes, biometric/genetic data processed to uniquely identify a person, personal information from a known child, and data revealing racial origin, religion, health diagnosis, sexual orientation, or citizenship/immigration status. The sensitive data we actually process in the ordinary course is precise geolocation of Operators/Drivers on a Job, Account login, and CDL / government identifiers. We do not seek the other listed sensitive categories.

21.3 Consent to precise geolocation (TIPA sensitive-data consent)

TIPA requires consent before processing a consumer’s sensitive data, including precise geolocation. Consent is a clear affirmative act signifying freely given, specific, informed, and unambiguous agreement.

Operators and Drivers consent to precise geolocation by using the application on a Job after this conspicuous notice. The Service cannot dispatch, geofence plants and dumpsites, compute dump wait time, display ETA to the Customer, substantiate tickets, or run the Rate Engine on real cycle times without that location. Location is required, not optional, for Operators on a Job (Section 3). Creating an Account, granting the OS location permission the app requests, and punching into or accepting a Job are the affirmative acts. If you are a TIPA consumer and you refuse that consent, do not accept Jobs; we cannot provide the Operator Service without precise location.

Customers consent to our processing of Operator location on their Jobs as a product feature they request, and to location of Customer Fleet or Hired Fleet vehicles when they use those modules.

21.4 TIPA consumer rights (if you are a covered consumer)

A Tennessee consumer (personal context) may, to the extent TIPA applies:

1. Confirm whether we are processing personal information about the consumer and access that personal information;

2. Correct inaccuracies;

3. Delete personal information provided by or obtained about the consumer, subject to exceptions;

4. Obtain a portable copy where processing is by automated means;

5. Opt out of (i) sale of personal information, (ii) targeted advertising, and (iii) profiling in furtherance of decisions that produce legal or similarly significant effects.

We do not sell personal information for money and do not use targeted advertising against Job GPS or CDL data. Rate Engine pricing of a Job is a commercial pricing engine for a B2B Marketplace, not consumer profiling of a natural person in a personal context, and not consumer credit. If you are nonetheless a TIPA consumer and wish to opt out of sale, targeted advertising, or profiling in furtherance of decisions that produce legal or similarly significant effects, email support@prohauls.co with subject “TIPA Opt-Out.” That opt-out does not require us to provide the Marketplace Service without the Rate Engine. Consistent with Terms Section 2.8.8 and Policy Section 6.1, the sole remedy for dissatisfaction with automated Marketplace Rates is to decline the Job and/or stop using the Marketplace.

Submit requests as in Section 19. We will authenticate and respond within 45 days, with one 45-day extension when reasonably necessary and with notice of the extension.

21.5 Appeal (60 days) and Tennessee Attorney General

If we deny a TIPA request, we will tell you why (unless the law permits us not to) and how to appeal. Appeal by replying to the denial, or by emailing support@prohauls.co with subject “TIPA Appeal,” within a reasonable time after the denial. We will decide the appeal, at no cost to you, within sixty (60) days of receipt, and we will provide a written explanation.

If the appeal is denied, you may contact the Tennessee Attorney General and Reporter:

Office of the Attorney General and Reporter
P.O. Box 20207
Nashville, TN 37202
https://www.tn.gov/attorneygeneral

Consumer resources: https://www.tn.gov/attorneygeneral/working-for-tennessee/consumer.html

TIPA is enforced by the Attorney General. It does not create a private right of action.

21.6 NIST Privacy Framework — written program; no certification claim

TIPA provides an affirmative defense to a controller or processor that creates, maintains, and complies with a written privacy program that reasonably conforms to the National Institute of Standards and Technology (NIST) Privacy Framework (currently “NIST Privacy Framework: A Tool for Improving Privacy through Enterprise Risk Management”), scaled to the entity’s size, complexity, activities, and the sensitivity of the data, and that provides the substantive rights TIPA requires. The program must be updated to reasonably conform to successor NIST or comparable frameworks within two years of publication.

Pro Hauls maintains a written information-privacy program that is intended to reasonably conform to the NIST Privacy Framework (and to successor or comparable frameworks) as a TIPA-aligned control, including Identify-Control-Communicate-Protect-type functions appropriate to a property-broker Marketplace of this scale. This statement is not a certification, audit opinion, ISO/NIST certificate, or representation that NIST or any third party has certified Pro Hauls. Conformance is an internal-control objective and a potential statutory defense, not a warranty to Users.

We and our service providers use cookies, pixels, local storage, SDKs, and similar technologies on the websites and, where the OS allows, in the apps, to:

• authenticate sessions and keep you logged in (necessary);
• remember Role and preferences (functional);
• measure traffic, crashes, and feature use (analytics);
• prevent fraud and scrape (security).

We do not, by default, use advertising cookies to sell or share personal information for cross-context behavioral advertising. If a marketing pixel is added later, we will update this Policy and provide any required opt-out.

You may block cookies in your browser. Necessary cookies may be required for login. We do not currently respond to browser DNT. If we are required to honor a universal opt-out (GPC) for “sale” or targeted advertising, we will for consumers as required; B2B Account Users are not consumers under TIPA and several other statutes. See Section 20.3. Default: we do not sell personal information and do not do cross-context behavioral advertising to consumers.

Third-party analytics (if used) are processors. Their own policies apply to any independent use they make, which we contract to restrict.

The Platform may link to FMCSA SAFER, insurer portals, mapping apps, app stores, or other sites we do not control. This Policy does not cover those sites. Their terms and privacy notices apply. We are not responsible for their content or practices. Connecting an ELD, TMS, scale, or accounting integration is at your direction; you are responsible for that vendor.

24.1 State privacy patchwork

If you are a “consumer” under another U.S. state privacy law (for example Virginia’s VCDPA, Colorado’s CPA, Texas’s DPSA, Connecticut, Oregon, Montana, and others as in force from time to time), we will honor non-waivable rights that actually apply to you. Many of those statutes still contain B2B, employment, FCRA, DPPA, and similar exceptions. This Policy does not create extra contractual rights beyond what the applicable statute requires. Submit requests as in Section 19. Providing a single inbox is not a concession that every state law applies, that you are a “consumer,” or that Pro Hauls has waived a statutory exception.

24.2 Nevada “do not sell” (NRS Chapter 603A)

Nevada residents may request that we not sell covered information under NRS Chapter 603A by emailing support@prohauls.co with subject “Nevada Do Not Sell.” We do not sell covered information as NRS 603A uses that term.

24.3 International; no EU establishment; no GDPR controller-in-the-Union rights

The Services are directed at the United States. Pro Hauls is established in Tennessee, United States. We process information in the United States. We do not maintain an establishment in the European Union, United Kingdom, or Switzerland for purposes of this Policy. This Policy does not contain a full GDPR “EU establishment” chapter.

If you access the Platform from outside the United States, you consent to transfer, storage, and processing in the United States, including processing that may be compelled by FMCSA, State agencies, and U.S. subpoenas, warrants, and court orders. United States law may not provide the same data-protection rights as your country. We do not offer GDPR “controller in the Union” rights, a GDPR Article 27 representative, or UK GDPR equivalent rights. Do not use the Platform if you cannot lawfully transfer operational GPS, CDL, and ticket data to the United States.

We may modify this Policy at any time. The Effective Date at the top will change. The current Policy is posted at https://www.prohauls.co/privacy-policy and in the apps. Material changes will be posted, and we may also notify you through the Platform, email, or SMS. Continued use after the effective date of a change constitutes acceptance to the extent Applicable Law permits. If a change requires additional consent (for example, a new biometric product, or a decision to sell personal information for money), we will obtain that consent before the new practice applies to you.

This Policy is not a promise that our practices will never expand within the purposes already described (Rate Engine improvement, new dump-related modules, additional verification vendors). It is a notice of categories, purposes, and rights.

This Policy is incorporated into the Terms. Privacy, data, TCPA, location, biometric, FCRA-process, and similar claims against Pro Hauls are subject to the Terms, including:

• Terms Section 13.15 — binding individual arbitration administered by the AAA under its Commercial Arbitration Rules; seat Nashville, Davidson County, Tennessee; class-action, collective, consolidated, and representative waiver; jury waiver;
• Terms Section 13.1 — exclusive Tennessee venue (Davidson County or Robertson County, Tennessee) for claims that proceed in court, including Pro Hauls’s injunctive and collection carve-outs;
• Terms Section 13.10 — one (1) year time limit on claims, to the extent permitted by Applicable Law;
• Terms Section 8 — limitation of liability (including the liability cap and the exclusion of consequential, incidental, and data-security damages).

This Policy does not create a separate private right of action, extra damages, a longer limitations period, or a warranty. Statutory rights that cannot be waived remain, and are still subject to the Terms’ procedural provisions to the maximum extent permitted (arbitration, class waiver, venue, one-year period, and Section 8). TIPA is enforced by the Tennessee Attorney General and does not create a private right of action (Section 21.5). Informal resolution under Terms Section 13.15(a) applies before arbitration.

If you timely opted out of arbitration under Terms Section 13.15(h), court claims still follow Section 13.1 exclusive Tennessee venue, the jury waiver in Section 13.15(f), Section 13.10, and Section 8.

Without limiting Terms Sections 13.11 and 13.15(d), Pro Hauls may seek injunctive or other equitable relief in the courts specified in Terms Section 13.1 (Davidson County or Robertson County, Tennessee) to protect intellectual property, Confidential Information, the Rate Engine, and the Platform, and to stop scraping, harvesting, doxxing Drivers or other Users, reverse engineering, or exfiltrating Platform data, without posting a bond to the extent permitted by Applicable Law, and without first arbitrating that request for equitable relief. Money damages for related claims remain subject to Terms Sections 13.15 and 8. User is not entitled to a reciprocal unbonded injunction against Pro Hauls under this Section.

Pro Hauls LLC
Attn: Privacy
302 Orlando Ave
Nashville, TN 37209
United States
Email: support@prohauls.co
Phone: 1-800-4PROHAUL (1-800-477-6428)

Web: https://www.prohauls.co/privacy-policy (also available in the Pro Hauls applications)

Support hours for operational issues are as stated in the Terms (generally 7:00 a.m. to 8:00 p.m. United States Central Time, Monday through Friday, excluding U.S. federal holidays, unless we publish different hours). Privacy requests are processed as Section 19 describes and may take the statutory period.

For legal notices under the Terms (as distinct from privacy requests), use the notice addresses in Terms Section 12, including contracts@prohauls.co for contract notices.

Questions about this document? Call (615) 477-0779 or email support@prohauls.app. Effective August 31, 2026.