Privacy Policy

1. Who this policy applies to

This Privacy Policy describes how Limousine Group Transportation LLC ("we," "us," or "the Company") collects, uses, and protects information through the LimoExtreme Driver mobile application ("the App").

The App is a workforce management tool used exclusively by drivers who provide ground transportation services under contract with us. It is not a consumer-facing application. Passengers and members of the general public do not use this App, and information about passengers is handled separately through our dispatch platform.

2. Information we collect

2.1 Account information

When you are onboarded as a driver, we receive your name, contact phone number, email address, driver's license information, and payment routing details necessary for paying you for services rendered.

2.2 Identity verification (selfie images)

The App captures still photographs of your face at:

• Initial enrollment (one-time baseline photo, taken by dispatch staff)
• The start of each work shift (going on duty)
• The completion of each trip

2.3 Location data

The App collects GPS coordinates (latitude, longitude, and accuracy) at the following moments:

• When you go on duty
• Every time you change a trip status (En Route, On Location, Passenger Onboard, Drop Off)
• At trip completion
• Continuously while you are on duty (see Section 4 for details)

2.4 Device information

For audit and security purposes we automatically log the device model, operating system version, app version, IP address, and timestamps of significant actions.

3. How we use this information

We use the information we collect strictly for the following business purposes:

• Verifying driver identity — ensuring the contracted driver, and not a substitute, is performing the work
• Trip auditing and billing — documenting that trips were started and completed at the correct locations and times
• Fraud prevention — detecting and preventing unauthorized substitution of drivers ("ghost-swapping")
• Dispatch operations — knowing which drivers are available and where they are so trips can be assigned efficiently
• Driver and passenger safety — locating drivers in emergencies
• Legal compliance and dispute resolution — producing records when required by law or in response to billing disputes, insurance claims, or contractor disagreements

We do not sell driver data to third parties. We do not use driver data for advertising. We do not use driver data to train artificial intelligence models.

4. Location data — foreground and background

4.1 Foreground collection

When the App is open and active on your device, location is collected at each meaningful action (going on duty, status changes, trip completion).

4.2 Background collection

While you are on duty, the App continues to collect location data even when the App is not in the foreground — for example, when your phone is locked, when the screen is off, or when you are using a different app for navigation. This is necessary so that:

• Your time on duty is accurately documented for payroll
• Trip pickup and drop-off locations can be verified
• Disputes with passengers or third parties can be resolved with location records

4.3 When location collection stops

Background location collection stops automatically when:

• You go off duty
• You sign out of the App
• You revoke location permissions in your device settings

The App does not collect location data when you are off duty.

4.4 Your control

You may disable location access at any time through your device settings (Settings → Privacy & Security → Location Services on iOS; Settings → Apps → LimoExtreme Driver → Permissions on Android). However, because location data is essential to performing dispatched trips and verifying work performed, the App will not function for on-duty driving when location is disabled.

5. Selfie images and face encodings

To prevent unauthorized substitution of drivers, the App uses face recognition technology to compare a selfie taken at the start of each shift and at trip completion against a baseline reference photo of you on file.

5.1 How it works technically

When you submit a selfie, the App produces a mathematical representation of your face called a "face encoding" (a 128-number vector). This encoding is compared to the encoding produced from your baseline reference photo. If the two encodings are sufficiently similar, the verification passes.

5.2 What we store

• The original baseline photograph (still image)
• The selfie photographs taken at each verification (still images)
• The numeric face encoding derived from the baseline
• The match score, timestamp, and outcome (pass/fail) of each verification

5.3 Where this data is stored

All biometric data is stored on private servers operated by us or by our infrastructure provider. We do not share biometric data with any third parties, do not transmit it to face-recognition services operated by Apple, Google, Amazon, Microsoft, or any other third-party vendor, and do not use it for any purpose other than verifying driver identity in the context of your work.

5.4 Biometric privacy notice (Illinois, Texas, Washington, and similar jurisdictions)

If you are providing services in a jurisdiction with specific biometric privacy laws — including but not limited to the Illinois Biometric Information Privacy Act (BIPA), the Texas Capture or Use of Biometric Identifier Act, and the Washington Biometric Privacy Act — your continued use of the App following enrollment constitutes written consent to:

• The collection of your biometric identifiers (facial features) and biometric information (face encodings)
• Their use solely for identity verification of you as a contracted driver
• Their storage on our secured servers
• The destruction of your biometric data within the timeframes described in Section 7

6. When we share information

We do not sell driver information. We share information only in these limited circumstances:

• Service providers — database hosting, payment processing, and software infrastructure providers that operate on our behalf under confidentiality obligations
• Affiliate transportation companies — when a trip is dispatched in partnership with an affiliate (such as Newark Limousine), driver identity (name, phone) and trip status updates are shared with that affiliate so they can coordinate the trip
• Law enforcement — when legally compelled by a valid subpoena, court order, or governmental request
• Insurance and legal proceedings — when necessary to defend against or pursue claims, including disputes with passengers, drivers, or third parties
• In a business transaction — if our company is merged, acquired, or sold, driver records may transfer to the new owner subject to the same protections in this policy

7. How long we keep information

• Account information: for as long as you remain an active driver, and for up to 7 years after the contractor relationship ends, for tax, payroll, and dispute purposes
• Trip records (status changes, GPS at status events, trip completion location): 7 years
• Selfie images and verification records: 3 years from the date taken, or until you cease being an active driver plus 12 months, whichever is shorter
• Face encodings (baseline): deleted within 30 days of you ceasing to be an active driver, or earlier on written request
• Background location pings (between status events): 90 days, then automatically deleted

8. Data security

We use industry-standard administrative, technical, and physical safeguards to protect driver data, including:

• Encryption of all data in transit over the internet (HTTPS/TLS)
• Encryption of biometric data at rest
• Restricted access to driver records limited to dispatch staff and authorized personnel
• Logging and monitoring of administrative access

No method of electronic transmission or storage is 100% secure, and we cannot guarantee absolute security.

9. Your rights and choices

You may, at any time:

• Request a copy of the personal information we hold about you
• Request correction of inaccurate information
• Request deletion of your biometric data (note: this will end your ability to work as a driver under our verification requirements)
• Revoke location permissions through your device settings (note: this will prevent you from going on duty)
• Withdraw your contractor relationship with us, after which your data will be retained only as required by Section 7

Drivers in California (under CCPA/CPRA), Virginia, Colorado, Connecticut, Utah, and other states or countries with comprehensive privacy laws have additional rights specific to those jurisdictions. To exercise any of these rights, contact us using the information in Section 12.

10. Children

The App is not intended for use by anyone under 18 years of age. We do not knowingly collect information from minors. If you believe a minor has used the App, contact us immediately so we can delete the information.

11. Changes to this policy

We may update this Privacy Policy from time to time. If we make material changes, we will notify active drivers through the App and by email at least 14 days before the changes take effect. The "Effective Date" at the top of this page indicates when the policy was last revised.