Mile Marker Safety — Privacy Policy

1. Scope and Relationship to FCRA

Mile Marker Safety Inc. ("Mile Marker Safety," "we," "us," or "our") respects your privacy. This Privacy Policy applies to personal information collected through our website, software platform, and mobile applications (collectively, the "Services").

• Customer Data (Data Processor Role): This policy does not apply to personal information processed on behalf of our motor carrier customers (“Customers”) when drivers (“Candidates”) apply for employment or submit compliance records. Our Customers’ respective privacy policies govern their use of candidate data. We process Candidate data strictly pursuant to our Customer contracts and instructions.
• FCRA Carve-Out: Personal information contained in consumer reports or investigative consumer reports (e.g., MVRs, PSP reports, background checks) gathered pursuant to the Fair Credit Reporting Act (FCRA) is governed by the FCRA and applicable federal statutes, not by this Privacy Policy.

2. Information We Collect

We collect information directly from you, automatically through your platform usage, and from third-party compliance sources.

A. Information Provided Directly

• Carrier Account Data: Business name, USDOT/MC number, administrative user names, email addresses, phone numbers, and billing details.
• Driver Candidate Data: Uploaded Commercial Driver’s Licenses (CDLs), passports, DOT Medical Cards, drug/alcohol testing records, employment history, and application responses uploaded by Candidates or Customers.
• Support & Communications: Information submitted when requesting technical support, participating in platform surveys, or communicating via our messaging tools.

B. Information Collected Automatically

• Technical Telemetry: IP addresses, browser types, operating systems, device identifiers, time zones, and dashboard navigation activity.
• AI & OCR Processing Data: Unstructured document image files uploaded to the platform (e.g., photos of CDLs or Medical Cards) processed by our Artificial Intelligence (AI) and Optical Character Recognition (OCR) systems to extract text data fields.

3. How We Use Your Information

We process personal information for the following business purposes:

• Service Delivery: To verify driver qualification files, track license and medical card expirations, generate safety scores, and process background checks requested by Customers.
• AI Model Improvement & Benchmarking: To create de-identified, aggregated, and anonymized datasets (“Aggregated Data”). We use Aggregated Data to train, refine, and improve our machine learning models, OCR extraction accuracy, and industry benchmarking tools. Aggregated Data contains no personally identifiable driver or carrier information.
• Administrative Operations: To authenticate users, prevent fraudulent activity, process subscription billing, and maintain information security.

4. Text Messaging & SMS Privacy (A2P 10DLC Compliance)

If you opt in to receive text messages (SMS) from Mile Marker Safety or through our platform on behalf of a Customer:

• No mobile information will be shared with third parties or affiliates for marketing or promotional purposes.
• All the above categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties or subcontractors, except service providers strictly assisting in the delivery of text messages.

5. How We Share Your Information

We do not sell personal information. We disclose personal information solely as follows:

• Prospective Employers / Customers: Candidate application data and compliance records are shared directly with the specific motor carrier to which the Candidate applied.
• Compliance Vendors & DMVs: Data is transmitted to authorized third-party vendors (e.g., state DMVs, FMCSA Clearinghouse, background check agencies) solely to execute searches ordered by the Customer.
• Cloud Infrastructure & Subprocessors: Data is hosted and processed by secure third-party service providers (e.g., AWS, Azure, payment processors) bound by strict confidentiality obligations.
• Legal & Regulatory Authorities: We may disclose data if required to do so by law, subpoena, court order, or official DOT/FMCSA safety audit request.

6. Data Security & Retention

• Security Safeguards: We enforce administrative, technical, and physical security controls, including Transport Layer Security (TLS 1.2+) for data in transit and AES-256 encryption for data at rest. Infrastructure is hosted in Tier-3/Tier-4 cloud facilities with role-based access controls and continuous vulnerability monitoring.
• Data Retention: We retain Customer and Driver data for the duration of the active subscription or as directed by the Customer to fulfill FMCSA record-retention requirements (e.g., 49 CFR Part 391). Upon contract termination, Customers are granted a 30-day retrieval period, after which live data is purged in accordance with our data disposal policies.

7. Your Privacy Rights & Driver Requests

Depending on your jurisdiction (e.g., California CPRA), you may have the right to access, correct, or delete your personal information.

• For Drivers/Candidates: Because Mile Marker Safety processes driver compliance data as a Service Provider on behalf of motor carriers, Drivers seeking to access, correct, or delete their application data must direct their requests to the prospective employer/carrier. We will assist the Carrier in responding to verified driver requests as contractually required.
• For Carriers/Admins: Account administrators may update account details directly within the platform settings or by contacting us.

8. Contact Us

For questions regarding this Privacy Policy or our data practices, please contact: Mile Marker Safety Inc., Attn: Privacy & Legal Department, Email: info@milemarkersafety.com, Address: 200 Continental Dr, Suite 401, Newark, DE, 19713.