PRIVACY POLICY

Introduction

This privacy policy (the "Privacy Policy") applies to all Services offered on the website www.sharetheload.com (the "Website") and by Sharetheload Limited ("Sharetheload") and it applies to all information collected on Users of Sharetheload's Services as well as visitors of the Website, cookies and other Personal Data that may be collected by the Website.

When you use Sharetheload, you trust us with your information. We are committed to keeping that trust. This policy describes the information we collect, how it is used and shared, your choices regarding this information, and our privacy practices, including what information we collect, when we collect it, and how we use it.

SUMMARY

Data collection and use

This policy applies to users of the Sharetheload services anywhere in the world, including users of Sharetheload apps, websites, features or other services.

This policy describes how Sharetheload and its affiliates collect and use personal information to provide our services. This policy specifically applies to:

• Senders: users who require parcel(s) delivered
• Travelers: users who provide delivery services individually
• Receivers: The end user who will receive the parcel(s).
• Visitors: Users who may access the website and/or its services from time to time.

This policy also applies to those who provide information to Sharetheload in connection with an application to use our services, or whose information is accessed via Sharetheload. All those subject to this policy are referred to as "users" for purposes of this policy.

The practices described in this policy are subject to applicable laws in the places in which we operate. This means that we only engage in the practices described in this policy in a particular country or region if permitted under the laws of those places. Please contact us if you have questions on our practices in your country or region.

Data controller

Sharetheload provides services to users throughout the world. Sharetheload is the data controller.

Sharetheload processes personal information inside and outside Hong Kong.

Questions, comments and complaints about Sharetheload's data practices can be submitted to Sharetheload's data protection office at dpo@sharetheload.com

We process personal information inside and outside Hong Kong. Sharetheload transfers information of users outside Hong Kong on the basis of mechanisms approved under applicable laws.

iii. The information we collect

Sharetheload collects:

• Information that you provide to Sharetheload, such as when you create your Sharetheload account.
• Information created when you use our services, such as location, usage and device information.
• Information from other sources, such as Sharetheload partners and third parties that use Sharetheload APIs.
• Information you provide to Sharetheload when signing up for our newsletter or receiving promotional information.
• Information, such as cookies, when you visit our Website. Please refer to separate cookie statement.

This information may include your name, email, phone number, login details, address, payment or banking information where required, government identification details, date of birth, profile photo, signature, travel route details, flight information, bookings, airline details, ratings, delivery status, verified status, and live location tracking where enabled.

This also includes the preferences and settings that you enable for your Sharetheload account.

Background check information: We may collect background check information if you sign up to use Sharetheload services. This may include information such as your history or criminal record and other watch list information (where permitted by law). A vendor may collect this information on Sharetheload's behalf that may process this data.

Demographic data: We may collect demographic information about you, including through user surveys. This includes information such as access dates and times, app features or pages viewed, app crashes and other system activity, type of browser and third-party sites or service you were using before interacting with our services. In some cases, we collect this information through cookies, pixel tags, and similar technologies that create and maintain unique identifiers. To learn more, please review our Cookie Statement.

Device information
We may collect information about the devices you use to access our services, including the hardware models, device IP address, operating systems and versions, software, file names and versions, preferred languages, unique device identifiers, advertising identifiers, serial numbers, device motion information, and mobile network information.

Communications data
We enable users to communicate with each other and Sharetheload through the Sharetheload Services, apps and websites. This means via calling or texting each other (in some countries, without disclosing their telephone numbers to each other). To provide this service, Sharetheload receives some information regarding the calls or texts, including the date and time of the call/text, and the content of the communications.

How we use your information

Sharetheload collects and uses information to enable reliable and convenient delivery of products and services. We also use the information we collect:

• To enhance the safety and security of our users and services
• For customer support
• For research and development
• To enable communications to or between users
• To provide promotions or contests
• In connection with legal proceedings

Sharetheload does not sell or share your personal information to third parties for third party direct marketing purposes.

Providing services and features

Sharetheload uses the information we collect to provide, personalise, maintain and improve our products and services. This includes using the information to:

• Create and update your account.
• Verify your identity.
• Enable you to send or deliver parcel services. This includes automated processing of your information in which the price of sending the parcel is determined based on market factors such as supply and demand, weight, region, zones, taxes and other applicable fees that may be applied including recovering costs and other surcharges
• Process or facilitate payments for those services.
• Offer, obtain, provide or facilitate insurance in connection with our services.
• To track the progress of the delivery.
• Enable features that allow you to share information with other people, such as when you submit a compliment about a sender or traveler, refer a friend to Sharetheload or share your time of departure and arrival.
• Enable features to personalise your Sharetheload account.
• Enable Accessibility features that make it easier for users with disabilities to use our services.
• Perform internal operations necessary to provide our services, including to troubleshoot software bugs and operational problems, to conduct data analysis, testing, and research, and to monitor and analyse usage and activity trends.

Safety and security

We use your data to help maintain the safety, security and integrity of our services and users. This includes, for example:

• Screening users before enabling access to our services, including background checks where permitted by law, to help prevent misuse of the platform.
• Using information from user devices to identify unsafe practices being carried out such as sending or delivering prohibited items.
• Our real-time ID check feature may prompt Sharetheload users to share a selfie before using certain services. This helps confirm that the person using the app matches the information provided, helping prevent fraud and protecting other users.
• Using device, location, profile, usage and other information to prevent, detect, and combat fraud or unsafe activities. This includes processing of such information, in certain countries, to identify practices or patterns that indicate fraud or risk of safety incidents. This may also include information from third parties. In certain cases such incidents may lead to deactivation by means of an automated decision-making process. Users may contact Sharetheload to exercise rights available under applicable privacy laws.
• Using user ratings to encourage improvement by affected users, and as grounds for deactivating users with ratings below a certain minimum as may be required in their region. Calculation and deactivation may be done through an automated decision-making process. Users may contact Sharetheload to exercise rights available under applicable privacy laws.

Customer support

Sharetheload uses the information we collect (including recordings of customer support calls after notice to you and with your consent) to assist you when you contact our customer support services, including to:

• Direct your questions to the appropriate customer support person
• Investigate and address your concerns
• Monitor and improve our customer support responses

Research and development

We may use the information we collect for testing, research, analysis and product development. This allows us to improve and enhance the safety and security of our services, develop new features and products, and facilitate insurance and finance solutions in connection with our services.

Communications among users

Sharetheload uses the information we collect to enable communications between our users. For example, a traveler may text or call a sender to confirm delivery location.

Communications from Sharetheload

Sharetheload may use the information we collect to communicate with you about products, services, promotions, studies, surveys, news, updates and events.

Sharetheload may also use the information to promote and process contests and sweepstakes, fulfil any related awards, and serve you relevant ads and content about our services and those of our business partners. You may receive some of these communications based on your profile as a Sharetheload user. Users may contact Sharetheload to exercise rights available under applicable privacy laws.

Legal proceedings and requirements

We may use the information we collect to investigate or address claims or disputes relating to your use of the Sharetheload services, or as otherwise allowed by applicable law, or as requested by regulators, government entities and official inquiries.

Cookies and third-party technologies

SUMMARY

Sharetheload and its partners use cookies and other identification technologies on our apps, websites, emails and online ads for purposes described in this policy.

Cookies are small text files that are stored on your browser or device by websites, apps, online media and advertisements. Sharetheload uses cookies and similar technologies for purposes such as:

• Authenticating users
• Remembering user preferences and settings
• Determining the popularity of content
• Delivering and measuring the effectiveness of advertising campaigns
• Analysing site traffic and trends, and generally understanding the online behaviours and interests of people who interact with our services

We may also allow third parties to provide audience measurement and analytics services for us, to serve advertisements on our behalf across the Internet, and to track and report on the performance of those advertisements. These entities may use cookies, web beacons, SDKs and other technologies to identify your device when you visit our site and use our services, as well as when you visit other online sites and services.

Please see our Cookie Statement for more information regarding the use of cookies and other technologies described in this section, including regarding your choices relating to such technologies.

Information sharing and disclosure

Some of Sharetheload's products, services and features require that we share information with other users or at your request. We may also share your information with our affiliates, subsidiaries and business partners, for legal reasons or in connection with claims or disputes.

Sharetheload may share the information we collect:

With other users

• For example, if you are a Sender, we may share your first and last name, ratings and/or feedback, address, pick up location, your photo and your verified status with travelers.
• If you are a Traveler, we may share information with your sender and receiver including first and last name, photo, verified status, live GPS location tracking where enabled, your declaration of goods and services, estimated time of departure, estimated travel time, method of travel or transportation, flight number, airline, rating provided by Senders, total number of trips, how long you have used the Sharetheload app, and contact information depending upon applicable laws. If you choose to become a traveler, we may also share information associated with that profile, including information you submit and compliments that past senders have submitted about you.
• If you are a receiver of the parcel, the shared information will be a tracking code which is provided solely by the Sender, information about the traveler, your location, your first and last name, address and location.

This includes sharing your information with:

• Other people at your request. For example, we may share your ETA and location with friends or family at your request.
• Sharetheload business partners. For example, if you requested a service through a partnership or promotional offering made by a third party, Sharetheload may share your information with those third parties. This may include, for example, other apps or websites that integrate with our APIs, or services, or those with an API or service with which we integrate, or business partners with whom Sharetheload may partner with to deliver a promotion, a contest or a specialized service.
• With the general public when you submit content to a public forum

We love hearing from our users, including through public forums such as blogs, social media and certain features on our network. When you communicate with us through those channels, your communications may be viewable by the public.

With the owner of Sharetheload accounts that you may use
If you use a profile associated with another party we may share your trip information with the owner of that profile. This occurs, for example, if you are:

• A Sender using a Business profile.
• A Traveler using an account owned by a logistics company or other parcel delivery company.
• A Sender who sends a parcel(s) arranged by a friend or under a Family profile.

With Sharetheload subsidiaries and affiliates
We share information with our subsidiaries and affiliates to help us provide our services or conduct data processing on our behalf. For example, Sharetheload processes and stores information in Hong Kong on behalf of its international subsidiaries and affiliates.

With Sharetheload service providers and business partners
Sharetheload may provide information to vendors, consultants, service providers, and business partners that help perform or provide the service. This may include payment processors, identity verification providers, cloud hosting providers, analytics providers, customer support tools, professional advisers, airports, customs authorities, airlines, or other delivery-related partners where required to provide the service or comply with law.

For legal reasons or in the event of a dispute
Sharetheload may share your information if we believe it is required by applicable law, regulation, operating agreement, legal process or governmental request, or where the disclosure is otherwise appropriate due to safety or similar concerns. This includes sharing your information with law enforcement officials, government authorities, airports (if required by the airport authorities as a condition of operating on airport property), or other third parties as necessary to enforce our Technology Services Agreement, Terms of Service, user agreements, or other policies, to protect Sharetheload's rights or property or the rights, safety or property of others, or in the event of a claim or dispute relating to your use of our services. If you use another person's credit card, we may be required by law to share information with that credit card holder, including information about the transaction. This also includes sharing your information with others in connection with, or during negotiations of, any merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or into another company.

With your consent
Sharetheload may share your information other than as described in this policy if we notify you and you consent to the sharing.

Information retention and deletion

Sharetheload retains user profile and other information for as long as you maintain your Sharetheload account. Once such information is no longer necessary to provide Sharetheload's services, enable customer support, enhance the user experience or for other operational purposes, Sharetheload takes steps to prevent access to or use of such information for any purpose other than compliance with these requirements or for purposes of safety, security and fraud prevention and detection.

Sharetheload retains transaction, location, usage and other information for 7 years in connection with regulatory, tax, insurance or other requirements in the places in which it operates. Sharetheload thereafter deletes or anonymises such information in accordance with applicable laws.

If you withdraw consent to the collection or use of personal information for optional features, such as features that use your calendar or address book, Sharetheload deletes such personal information.

Users may request deletion of their accounts at any time. Following such request, Sharetheload deletes the information that it is not required to retain, and restricts access to or use of any information it is required to retain. You may request deletion of your account at any time through the privacy settings in the Sharetheload app, or via Sharetheload's website.

Following such requests, Sharetheload deletes the information that it is not required to retain. In certain circumstances, Sharetheload may be unable to delete your account, such as if there is an outstanding credit on your account or an unresolved claim or dispute. Upon resolution of the issue preventing deletion, Sharetheload will delete your account as described above.

Sharetheload may also retain certain information if necessary for its legitimate business interests, such as fraud prevention and enhancing users' safety and security. For example, if Sharetheload shuts down a user's account because of unsafe behaviour or security incidents, Sharetheload may retain certain information about that account to prevent that user from opening a new Sharetheload account in the future.

Special information for EU users and EU Citizens

This section summarises Sharetheload's grounds for processing personal information under GDPR, and the rights of EU users and citizens as relates to Sharetheload's handling of personal information.

As of 25 May 2018, the processing of personal data of users in the European Union is subject to the EU General Data Protection Regulation ("GDPR"). This section provides information as relates to EU users' rights, and Sharetheload's responsibilities, under this regulation.

11.1 EU user rights

If you are a Sharetheload user in the EU or are an EU citizen, you have the following rights with respect to Sharetheload's handling of your personal information. To exercise these rights, please see below or submit your request to dpo@sharetheload.com

Users outside the EU may also request explanation, correction, deletion or copies of their personal data dpo@sharetheload.com

Explanation and copies of your data

• You have the right to request an explanation of the information that Sharetheload has about you and how Sharetheload uses that information.
• You also have the right to receive a copy of the information that Sharetheload collects about you if collected on the basis of consent or because Sharetheload requires the information to provide the services that you request.

Correction

If Sharetheload has information about you that you believe is inaccurate, you have the right to request correction of your information. Please see the section titled "Explanation, copies and correction" below for more information on correcting, or requesting correction of, your information.

Deletion

Users may request deletion of their accounts at any time. Users may request deletion through the Privacy settings menu in the Sharetheload app, or via Sharetheload's website. We may retain certain information about you as required by law and for legitimate business purposes permitted by law.

Please see the "Information retention & deletion" section above for more information regarding Sharetheload's retention and deletion practices.

Objections and complaints

Users in the EU have the right to object to Sharetheload's processing of personal data, including for marketing purposes based on profiling and/or automated decision-making. Sharetheload may continue to process your information notwithstanding the objection to the extent permitted under GDPR.

Users in the EU also have the right to file a complaint relating to Sharetheload's handling of your personal information with the relevant authority in your own country

You may also submit questions, comments or complaints to Sharetheload's data protection officer.

11.2. Grounds for processing

GDPR requires that companies processing the personal data of EU users do so on the basis of specific legal grounds. As described below, Sharetheload processes the information of EU users based on one or more of the grounds specified under GDPR:

This processing is necessary to provide the services and features you request

Sharetheload must collect and use certain information in order to provide its services. This includes:

• User profile information that is necessary to establish and maintain your account, including to verify your identity; enable communications with you about your orders and accounts; deliveries and to enable you to make or receive payments.
• Background check information necessary to enable users to request or provide services through the Sharetheload app.
• User location information, which is necessary to match Senders with Travelers and to track parcels in real time while in progress.
• Transaction information, which is necessary to generate and maintain in connection with your use of Sharetheload services.
• Usage information, which is necessary to maintain, optimise and enhance Sharetheload's services, including to determine, sometimes in combination with other information, incentives, connect Senders and Travelers, and calculate costs of sending parcel(s) and/or receiving payments.
• Collection and use of this information is a requirement for using Sharetheload's apps.

The processing is necessary to protect the vital interests of our users or of others

Sharetheload may process personal information, including disclosing data to law enforcement authorities in case of threats to the safety of users or of others.

The processing is necessary for Sharetheload's legitimate interests

Sharetheload collects and uses personal information to the extent necessary for its legitimate interests. This includes collecting and using information:

• To maintain and enhance our users' safety and security. For example, we collect background check information (where permitted by law) to prevent unsafe users from providing services through our apps. We also use personal information to prevent use of our services by users who have engaged in inappropriate or dangerous behaviour, such as by retaining information of banned users to prevent their use of Sharetheload apps. We also use usage information to prevent matching of senders and travelers for whom there is higher risk of conflict (e.g. because they have been the subject of prior complaints from other users).
• To prevent, detect and combat fraud in connection with the use of our services. For example, Sharetheload uses user profile, location, device and usage information to identify and prevent circumstances when users attempt to defraud Sharetheload or other users.
• To inform law enforcement officials regarding criminal acts or threats to public safety.
• To provide customer support.
• To optimise our service and develop new services. This includes, for example, identifying the best pick-up/drop-off locations, recommending (new) features, improving navigation, enhancing pricing and matching senders, travelers, receivers, and delivery partners.
• For research and analytical purposes. This includes, for example, analysing usage trends to improve the user experience and enhance the safety and security of our services.
• For direct marketing purposes. This includes, for example, analysing data to identify trends and tailor marketing messages to user needs.
• To enforce Sharetheload's Terms of Service.

The processing is necessary for the legitimate interests of other persons or parties

Sharetheload collects and uses personal information to the extent necessary for the interests of other persons or the general public. This includes sharing information in connection with legal or insurance claims, to protect the rights and safety of others.

Sharetheload may also process personal information when necessary in regards to a substantial public interest, on the basis of applicable laws.

The processing is necessary to fulfil Sharetheload's legal obligations

Sharetheload is subject to legal requirements in the jurisdictions in which it operates that require us to collect, process, disclose and retain your personal data. For example, Sharetheload is subject to laws and regulations in many cities and countries that require it to collect and retain information about the services provided, to retain such information for extended periods of time, and to provide copies of such information to governmental or other authorities. Sharetheload uses your information to comply with such laws to the extent they apply to your use of the Sharetheload apps.

Sharetheload may also share information with law enforcement, or requests by third parties pursuant to legal processes.

Consent

Sharetheload may collect and use your information on the basis of your consent. You may revoke your consent at any time. If you revoke your consent, you will not be able to use any service or feature that requires collection or use of the information we collected or used on the basis of consent.

Sharetheload relies on consent in connection with data collections or uses that are necessary to enhance the user experience, to enable optional services or features, or to communicate with you. If you are an EU user or citizen, the following types of data are collected or used on the basis of your consent.

• Location information
• Share live location
• Notifications: Account and service updates
• Notifications: Discounts and news
• Address book/contacts
• Calendar syncing
• Accessibility features

Please see the choice & transparency section below for further information about these types of data collection and use, how to opt in or out of them, and the effect of opting out of these on your use of Sharetheload's apps.

Sharetheload may also collect personal information about you through voluntary surveys. Your responses to such surveys are collected on the basis of consent and will be deleted once no longer necessary for the purposes collected.

Choice and transparency

Sharetheload provides means for you to see and control the information that Sharetheload collects, including through:

• in-app privacy settings
• device permissions
• in-app ratings pages
• marketing opt-outs

You may also request that Sharetheload provide you with explanation, copies or correction of your data.

Privacy Settings

Location information

Sharetheload uses users' device location services to make it easier to send and/or deliver parcel(s) in a safe, secure and cost-effective way whenever you use the services of Sharetheload. Location data helps improve our services, including pick-ups, parcel tracking and customer support.

You may enable/disable or adjust Sharetheload's collection of your ("Users") information at any time through the Privacy settings menu in the Sharetheload app or via the settings on your mobile device. You may use the Sharetheload app if you have not enabled location sharing, but it may be more difficult to match, track, or complete a delivery handoff.

Notifications: Account updates

Sharetheload provides users with the status notifications and updates related to your account. These notifications are a necessary part of using the Sharetheload app and cannot be disabled. However, you may choose the method by which you receive these notifications through the Privacy settings menu in the Sharetheload app.

Notifications: Discounts and news

You may enable Sharetheload to send you push notifications about discounts and news from Sharetheload. You may enable/disable these notifications at any time through the Privacy settings menu in the Sharetheload app.

Address book/contacts

You may enable Sharetheload to periodically sync with the address book/contacts information on your mobile device and store your contact information on our servers. This includes the names, phone numbers, email addresses and other information that you store in your address book contacts. This information is necessary to enable features such as making personalised recommendations for you and other users.

You may enable/disable contact syncing at any time via the Privacy settings menu in the Sharetheload app. If you disable contact syncing, you will not be able to use features that use your contacts' information.

Calendar syncing

You may enable Sharetheload to access and store the calendar data on your mobile device. Your calendar data might include event titles; responses (yes, no, maybe); start and end time of event; associated location descriptions; and number of attendees. We use this information to suggest destinations based on your calendar events and to customise your Sharetheload experience.

You may enable/disable calendar syncing at any time through the Calendar shortcuts menu under the Settings menu of the Sharetheload app. If you disable calendar syncing, you will not be able to use features that use your calendar information.

DEVICE PERMISSIONS

Most mobile platforms (iOS, Android, etc.) have defined certain types of device data that apps cannot access without your consent. These platforms have different permission systems for obtaining your consent. The iOS platform will alert you the first time the Sharetheload app wants permission to access certain types of data and will let you consent (or not consent) to that request. Android devices will notify you of the permissions that the Sharetheload app seeks before you first use the app. Your use of the app constitutes your consent.

RATINGS LOOK-UP

After every delivery, "Users" (Senders and Travelers) are able to rate each other, as well as give feedback on how the delivery went. This two-way system holds everyone accountable for their behaviour. Accountability helps create a respectful, safe environment for users of the Sharetheload platform. Ratings are made available on the dashboard of the app.

EXPLANATIONS, COPIES AND CORRECTION

You may request that Sharetheload:

• Provide a detailed explanation regarding the information Sharetheload has collected about you and how it uses that information.
• Receive a copy of the information Sharetheload has collected about you.
• Request correction of any inaccurate information that Sharetheload has about you.

You can make these requests by contacting Sharetheload at customerservice@sharetheload.com.

Any changes made via the app or by request will be subject to authentication and verification measures. Your service history can be found via the app for all services you may have requested or taken on behalf of other users.

MARKETING OPT-OUTS

You may opt out of receiving promotional emails from Sharetheload by emailing us optout@sharetheload.com. Please note that if you opt out, we may still send you non-promotional messages, such as receipts for your trips or information about your account.

Updates to this policy

We may occasionally update this policy. If we make significant changes, we will notify you through the Sharetheload apps or by other appropriate means, such as email. To the extent permitted under applicable law, by using our services after such notice, you consent to the updated policy.

We encourage you to periodically review this policy for the latest information on our privacy practices.