PRIVACY POLICY

1. Purpose and scope of the present Policy

Truckly Network operates a community application for professional truck drivers in the United States (the "Application"), distributed through the Apple App Store and Google Play. The present Privacy Policy (the "Policy") identifies the categories of personal information collected through the Application, the manner in which each category is obtained, the purposes for which it is used, the recipients to whom it is disclosed, the periods for which it is kept, and the rights that may be exercised in respect of it.

Coverage extends to the Application, to the backend services that support it, and to the web pages published at https://truckers-network.com, including the account deletion page at https://truckers-network.com/account/delete. Services operated by other parties, which a user may reach through a link, remain outside that coverage, and their own notices govern any information they collect.

Two further documents complete the framework. The Terms of Use and End User License Agreement govern conduct within the Application, including the moderation of content and the consequences of misuse. The account deletion page describes the procedure by which an account is closed, together with the information that is erased and the information that is preserved. Where a summary of the Policy appears elsewhere, whether in a store listing or in a help article, the text set out below prevails.

Throughout the Policy, "we", "us", and "our" denote Truckly Network in its capacity as operator of the Application, while "you" and "the user" denote the individual who installs, registers for, or otherwise makes use of it.

2. Operator of the Application, and contact details

The Application is operated by Truckly Network, of Str. Puskin 32, Chisinau, Republic of Moldova, which determines the purposes and means of the processing described in the Policy.

Correspondence is received at a single electronic mail address, support@trucker-network.com, and it is monitored. General assistance and questions concerning the operation of the Application, requests to exercise privacy rights, including access, correction, portability, and deletion, complaints concerning the handling of personal information, and reports of harmful or unlawful content, of abusive conduct, or of any matter affecting the safety of a minor are all directed to that address, which additionally serves as our designated point of contact for child safety matters. So that a message reaches the appropriate person without delay, the subject line should identify the matter, using the words "Privacy request", "Delete my account", "Appeal", or "Child safety" according to the case.

Correspondence may also be delivered by post to the address stated above. Replies are issued by electronic mail unless the person concerned requests another means of delivery and provides the particulars necessary for it.

3. Minimum age, and the treatment of information relating to children

Registration is restricted to individuals who have reached the age of 13. At registration the user is required to confirm that the minimum age is met, and acceptance of the Terms of Use and End User License Agreement is recorded at the same moment. A user who has not yet reached the age of 18, or the age of majority applicable in the state of residence, may use the Application only with the knowledge and consent of a parent or legal guardian, who assumes responsibility for the conduct of the minor within the service.

No date of birth is requested, and no technique of age estimation or age assurance is applied to photographs, voice, or behavior. The consequence deserves to be stated plainly rather than concealed: age screening rests on the declaration made at registration, on the age rating applied by each application store, and on reports received from users and from the moderation process.

Personal information is not knowingly collected from a child under 13. Where we learn, whether through a report, through moderation, or through any other means, that an account has been opened by a child under that age, access is suspended immediately and the account, together with the personal information associated with it, is erased without undue delay and in any event within 30 days of confirmation. A parent or legal guardian who believes that a child under 13 has supplied personal information through the Application may write to support@trucker-network.com, and the same procedure is applied.

Our handling of such cases follows the Children’s Online Privacy Protection Act, 15 U.S.C. §§ 6501 to 6506, and the Children’s Online Privacy Protection Rule, 16 C.F.R. Part 312, the amendments to which were published in the Federal Register on 22 April 2025, took effect on 23 June 2025, and became fully applicable on 22 April 2026. Provisions on the prevention of child sexual abuse and exploitation, on the mechanism through which users report such material, and on our reporting obligations under 18 U.S.C. § 2258A appear in the Terms of Use and End User License Agreement.

4. Categories of personal information collected

4.1 Information supplied at registration and in the user profile

Authentication rests on a single credential, the mobile telephone number, to which a one-time passcode is delivered by short message. Registration cannot be completed without it, and no alternative method of sign-in, whether through a social network or otherwise, is offered within the Application. A display name is likewise required, since content and messages are attributed to it.

Every remaining field of the profile is optional and may be completed, altered, or left empty at the discretion of the user. Those fields comprise the full name, an electronic mail address, the company or employer, the home base, the trailer type, the number of years of experience, a profile photograph, the interface language, the preferred translation language, and the profile-sharing code by which another driver may locate the profile.

4.2 Commercial driver’s license verification information

A driver who wishes to obtain a verified status may submit the number of the commercial driver’s license held under the standards of 49 C.F.R. Part 383, the expiration date of that license, and photographs of its front and its back. Participation is entirely voluntary, the remaining functions of the Application are available to a driver who declines, and the flow may be abandoned at any point before submission. Storage, access, and retention arrangements applicable to those documents are described in Section 8, which should be read as an integral part of the present Section.

4.3 Content created by the user within the Application

The Application exists in order to allow drivers to publish and exchange information, so a substantial part of the personal information held by us consists of content produced by users themselves. Alerts consist of a text description, a location chosen by the author on the map, and, where the author elects to add them, photographs or video. Comments and votes are recorded against the alerts to which they relate.

Messages exchanged in one-to-one chats and in community group chats may contain text, photographs, video, voice messages, documents, and locations shared deliberately by the sender, together with reactions applied to individual messages. A copy of the conversations belonging to the user is also held in a local database on the device, so that chats open without delay and remain readable when connectivity is unavailable.

4.4 Participation in communities and in voice rooms

Records are kept of the communities of which the user is a member, of the voice rooms joined and the moment of joining, of any cool-down period applied after removal from a room, and of reports submitted by the user against content or against other users. Section 9 explains what is, and what is not, retained in relation to live audio.

4.5 Information generated automatically by the device and by the service

While the Application is open, the device may supply precise coordinates obtained from the satellite positioning system, the treatment of which is governed by Section 7. Independently of location, the service records the push notification token allocated to the device, the language configured on the device, session refresh tokens issued for the purpose of keeping the user signed in, and records of one-time passcode requests, which serve to detect and to limit abuse of the sign-in mechanism.

Moderation activity generates its own records, comprising complaints received, the assessment made, and the action taken. Notification preferences are stored as configured by the user, including the setting that suppresses the display of message text within push notifications.

4.6 Categories of information that are deliberately not collected

An accurate statement of what is absent is as informative as an inventory of what is present, and the following categories are not collected at all. No analytics software of any kind is embedded in the Application, whether supplied by Google, by Amplitude, by Mixpanel, by AppsFlyer, or by any comparable provider. No crash reporting service is embedded, so neither Crashlytics nor Sentry receives information from the Application.

No advertising or tracking software development kit is present, no advertising identifier is read, no identifier for advertisers is requested, and the App Tracking Transparency prompt is accordingly neither displayed nor required. Advertising is not sold or served within the Application in any form.

The address book of the device is never accessed, and contacts are never uploaded. No payment information is collected, because the Application is supplied at no cost and contains neither purchases nor subscriptions. No date of birth is requested. Biometric templates are not collected: where Face ID or a fingerprint is used to open an internal administrative screen, the comparison is performed by the operating system on the device itself, and no biometric identifier reaches our servers. Background location is not requested on either platform, and the permission that would permit continuous tracking is not sought.

5. Sources from which the information is obtained

Most of the information described above is supplied directly by the user, whether at registration, in the profile, in the verification flow, or through the act of publishing content and sending messages. A second source is the device itself, which supplies coordinates, the push token, and the configured language through the interfaces exposed by the operating system, in each case only after the corresponding permission has been granted.

A third source consists of other users, whose reports may identify an account, describe conduct attributed to it, and attach the content complained of. A fourth and narrow source consists of our service providers, which return technical results such as the delivery status of a short message or the failure of a push token, without supplying any new information about the individual concerned.

6. Purposes for which personal information is used

Authentication and account management constitute the first purpose. The telephone number and the one-time passcode establish that the person signing in controls the number registered, session tokens maintain that state, and the profile allows other drivers to recognize the account.

Delivery of the functions of the Application constitutes the second purpose, and it accounts for the majority of the processing. Alerts must be published, associated with a location, and displayed to other drivers. Comments, votes, and reactions must be attributed. Messages must be transmitted, stored, and made available across sessions. Voice rooms must be created, joined, and administered. Push notifications must be delivered, which requires the token and, unless the user has suppressed message previews, a limited extract of the message.

Proximity notification constitutes a distinct purpose that justifies the retention of a single location record. When an alert is published, drivers whose last known position lies near the point in question may be notified, so that a hazard reaches those able to act upon it.

Verification of a commercial driver’s license, where the user elects to undergo it, serves to confirm that the account belongs to a professional driver and to reduce impersonation within a community whose value depends on the credibility of its participants.

Moderation, safety, and the protection of minors constitute a further purpose, and it may require the examination of content, of reports, and of the records associated with an account, together with the suspension or removal of accounts and the reporting of material to the competent authorities where the law so requires.

Security, prevention of fraud, and prevention of abuse justify the retention of passcode request records, of session data, and of records concerning banned accounts, without which the sign-in mechanism could be exploited and enforcement measures could be circumvented by immediate re-registration.

Support and communication with users constitute the seventh purpose, since correspondence sent to our published address must be read, answered, and retained for a period sufficient to demonstrate what was requested and what was done.

Compliance with legal obligations, the establishment and defense of legal claims, and the enforcement of our Terms of Use and End User License Agreement constitute the final purpose, which operates as a limited exception to the retention rules described in Section 16.

7. Precise location information

Location is treated in a manner deliberately narrower than that adopted by many comparable services, and the details below describe the arrangement exactly as it is implemented.

Coordinates are obtained only while the Application is in the foreground. On iOS the permission requested is "While Using the App", and the "Always" permission is never requested. On Android no background location permission is requested. Where the operating system indicates that location is unavailable or that permission has been refused, the Application continues to function, although alerts must then be positioned manually and proximity notifications cannot be delivered.

Three distinct uses arise. When an alert is created, the author selects its position on the map, and the coordinates so chosen are published within the feed and become visible to other users, which makes them public information by the deliberate act of the author. Separately, the last known position of the device is written to a table that holds exactly one record for each user, overwritten at every update, so that no history of movement is accumulated at any time; its sole function is the proximity notification described in Section 6. Finally, the position of the device is used to center the map on the screen, an operation performed on the device itself.

Where the map is displayed, the tile images are requested from CARTO, and the provider is able to infer the geographic area being viewed from the identity of the tiles requested, together with the internet protocol address of the device. When a place is searched by name, the text of the query and the internet protocol address reach the OpenStreetMap Foundation, which operates the Nominatim service. When an alert is created, the coordinates are converted into a "City, ST" label by the geocoder built into the operating system, supplied by Apple on iOS and by Google on Android.

Permission may be withdrawn at any moment through the settings of the operating system, without any action within the Application. Withdrawal stops further collection immediately. The single stored record of the last known position is erased when the account is deleted, and may be erased on request at any earlier time by writing to support@trucker-network.com.

8. Commercial driver’s license documents

Photographs of a commercial driver’s license, and the license number itself, receive treatment different from that applied to any other category of information handled by the Application, and the difference is deliberate. Under the privacy legislation of California a driver’s license number falls within sensitive personal information, as defined at Cal. Civ. Code § 1798.140(ae)(1)(A). Under the security and breach notification statutes of several states, the same element attracts specific obligations, among them the duty to implement and maintain reasonable security procedures under Cal. Civ. Code § 1798.81.5(b), the duty to develop, implement, and maintain reasonable safeguards under N.Y. Gen. Bus. Law § 899-bb(2)(a), and the duty to protect and to destroy records containing sensitive personal information under Tex. Bus. & Com. Code § 521.052.

Verification is optional, and the information is collected on the basis of the express and separate consent given by the driver at the moment of submission. Consent may be withdrawn at any time by writing to support@trucker-network.com, in which case the documents are erased and the verified status is removed.

Storage takes place in a private area of the object storage service described in Section 11, and not in the area used for ordinary media. Access is possible only through a temporary link that expires 10 minutes after it is generated, and it is granted exclusively to an administrator of the platform who is reviewing the verification request. No other user of the Application, and no automated public link, can reach the documents.

Retention is limited by design. Once the verification request has been decided, whether it is approved or refused, the photographs of the license are erased as soon as the decision has been recorded, and in any event no later than 30 days after that decision. What survives the erasure is the outcome of the verification, the expiration date of the license, which allows the verified status to lapse when the license itself expires, and a record that a decision was taken and when. Where an allegation of fraud, an active dispute, a security incident, or a legal obligation requires it, the documents may be preserved beyond that period, in which case retention is confined to what the specific matter requires and ends when the matter is resolved.

No commercial driver’s license information is disclosed to any other user, sold, shared, or used for any purpose other than verification, security, and compliance with legal obligations.

9. Voice rooms, and voice messages sent within chats

Live audio and recorded audio are two different things, and confusion between them would misrepresent the service, so each is described separately.

Voice rooms are never recorded and never stored, whether by us or by any other party. Audio travels in real time over a WebRTC connection, encrypted in transit through DTLS-SRTP, and passes through a selective forwarding unit operated on our own server; each packet is discarded as it passes. The recording module of the underlying software is not deployed at all, no storage location for recordings exists, and the access tokens issued to participants confer only the permissions required to join a room, to publish audio, and to receive audio. The permission that would allow a recording to be made is granted to no one. Audio never reaches the application backend, whose role is confined to the issuing of tokens, the administration of rooms, and the receipt of technical events.

What is retained in relation to a voice room is metadata alone, without any audio: the name of the room, its image, its language, its access type, the participant limit, the number of participants, an indicator of whether the room is live, the identity of the user who created it, a record of who joined and when, and any cool-down period applied following removal. A room in which no activity occurs is deleted automatically after 15 days.

Voice messages sent within a chat follow a different logic altogether. The sender records such a message deliberately, and the resulting audio file is uploaded to our object storage and retained in the same manner as any other attachment, remaining available to the participants in the conversation until it is deleted or until the account is closed.

Recording of a voice room by a participant, whether through the device, through screen capture, or through external equipment, is prohibited by the Terms of Use and End User License Agreement. The prohibition exists because the law governing the recording of conversations differs from state to state. Federal law permits recording with the consent of a single party under 18 U.S.C. § 2511(2)(d), whereas the statutes of several states require the consent of every party, among them Cal. Penal Code § 632, 720 ILCS 5/14-2, Fla. Stat. § 934.03, RCW 9.73.030, 18 Pa. C.S. § 5703, Md. Code, Cts. & Jud. Proc. § 10-402, Mass. Gen. Laws ch. 272, § 99, and Mont. Code Ann. § 45-8-213. Responsibility for compliance with the law of the applicable jurisdiction rests with the user who makes a recording, and any such recording is made without our knowledge, without our authorization, and outside the service.

10. Translation performed on the device

Alerts may be translated between languages, and the operation is performed entirely on the device. When a language is first used, the corresponding model file is downloaded from Google, an operation that reveals the request for a model and the internet protocol address of the device, and nothing further. The text of an alert, of a comment, or of a message is never transmitted to Google or to any other translation service, and no translated text leaves the device. Deletion of a downloaded model, where the user wishes to remove it, is performed through the settings of the Application or by uninstalling it.

11. Service providers and other recipients of personal information

The parties identified below are the complete set of external recipients of personal information, each engaged for a defined technical function. Where a provider is engaged under a contract, that contract restricts the use of the information to the provision of the service requested by us, prohibits its use for the provider’s own purposes, and requires the maintenance of protections at least equivalent to those described in the Policy, and a data processing agreement is concluded wherever the nature of the service calls for one. Certain of the services described below, among them the search by place name, the geocoding performed by the operating system of the device, and the download of translation model files, are public interfaces used under the published terms of their operators rather than under a negotiated contract, and the information reaching them is confined to what is described in the relevant paragraph. No recipient is permitted to sell the information, to share it for advertising purposes, or to retain it beyond the period necessary for the function performed.

11.1 Railway Corporation, United States

Railway hosts the application backend, the PostgreSQL database, and the Redis cache, and therefore processes every category of information described in Section 4 in the course of hosting it. Its privacy policy is published at https://railway.com/legal/privacy.

11.2 Cloudflare, Inc., United States

Cloudflare supplies the S3-compatible object storage in which profile photographs, alert photographs and video, chat attachments, voice messages, and commercial driver’s license documents are held. Its privacy policy is published at https://www.cloudflare.com/privacypolicy/.

11.3 Twilio Inc., United States

Twilio delivers the one-time passcodes used for sign-in through its Verify service, and receives the mobile telephone number for that sole purpose. Its privacy notice is published at https://www.twilio.com/en-us/legal/privacy. Message and data rates applied by the mobile network operator of the user are a matter between the user and that operator.

11.4 Google LLC, United States, in respect of Firebase Cloud Messaging

Firebase Cloud Messaging delivers push notifications, and receives the device push token, the device language, and the payload of the notification, which comprises the name of the sender, up to 120 characters of the message text, and the address of the sender’s profile photograph. Where the user has enabled the setting that hides message previews, the text of the message is not transmitted. Information concerning the handling of data by the service is published at https://firebase.google.com/support/privacy, and the general privacy policy of Google is published at https://policies.google.com/privacy.

11.5 Apple Inc., United States, in respect of the Apple Push Notification service

On iOS, notifications reach the device through the Apple Push Notification service, which is addressed by way of Firebase and receives the same payload. The privacy policy of Apple is published at https://www.apple.com/legal/privacy/.

11.6 CARTO, United States and European Union

CARTO supplies the raster basemap tiles displayed within the Application, and receives the internet protocol address of the device together with the identifiers of the tiles requested, from which the area being viewed may be inferred. Its privacy notice is published at https://carto.com/privacy.

11.7 OpenStreetMap Foundation, United Kingdom and European Union

The Nominatim service operated by the OpenStreetMap Foundation performs searches by place name, and receives the text of the query together with the internet protocol address of the device. Its privacy policy is published at https://osmfoundation.org/wiki/Privacy_Policy.

11.8 Apple Inc. and Google LLC, in respect of geocoding performed by the operating system

Conversion of coordinates into a locality label is carried out by the geocoder built into the device, supplied by Apple on iOS and by Google on Android, and the coordinates are transmitted to the respective provider for that operation alone.

11.9 Google LLC, in respect of translation model files

Model files for on-device translation are downloaded from servers operated by Google, as described in Section 10. No user content is transmitted in the course of that download.

11.10 Hetzner Online GmbH, Germany

A virtual server rented from Hetzner hosts the voice infrastructure operated by us, together with the relay used to establish connections and the domain proxy. Voice traffic passes through that server in real time and is not stored, while the identifier, the display name, and the address of the profile photograph of a participant are processed for the purpose of administering the room. The privacy policy of Hetzner is published at https://www.hetzner.com/legal/privacy-policy/. The voice software installed on that server is operated by us and not by its author, which is therefore not a recipient of personal information.

11.11 Porkbun LLC, United States

Porkbun provides domain registration, name resolution, and electronic mail forwarding for truckers-network.com, the domain on which the web pages of the Application are published, including the account deletion page. No other application information reaches it. Its privacy policy is published at https://porkbun.com/legal/agreement/privacy_policy.

11.12 Google LLC, United States, in respect of the published electronic mail address

The electronic mail address published for contact throughout the Policy is hosted on a domain whose incoming mail is routed to the mail service operated by Google, which accordingly receives and stores the content of every message sent to that address, the address of the sender, and any attachment supplied. Correspondence of that kind may include a privacy request, a report concerning content or the safety of a minor, and any further information the sender chooses to include. The general privacy policy of Google is published at https://policies.google.com/privacy.

12. Content that is public within the Application, and links to media that are not access-controlled

Alerts, the photographs and video attached to them, comments, votes, display names, and profile photographs are visible to other users of the Application, and material of that kind should be regarded as public. A user who does not wish an item to be seen should not publish it.

A further point requires candid disclosure. Profile photographs, alert media, and chat attachments are stored in the object storage with public read access by direct link. The addresses of those files are long and are not guessable, yet they are not protected by authentication, so any person who obtains such an address, whether because it was forwarded, copied, or otherwise disclosed, is able to open the file without signing in. The arrangement is common among messaging applications, and it is described here rather than glossed over, so that users may make an informed decision about the material they upload. Documents relating to commercial driver’s license verification are the sole exception, and they are protected as set out in Section 8.

Content that has been received by another user may persist on that user’s device even after the sender deletes it, since a copy of a conversation is held locally as described in Section 4.3. Deletion within the Application removes the item from our systems and from the interface, and it cannot recall a copy already delivered to a recipient or captured by means of a screenshot.

13. Disclosure for legal, safety, and corporate reasons

Personal information may be disclosed where disclosure is required by applicable law, by a subpoena, by a court order, or by another binding demand issued by a competent authority, and where, in our reasonable judgment, disclosure is necessary in order to comply with a legal obligation.

Disclosure may also occur where it is necessary in order to protect the rights, property, or safety of a user, of a third party, or of the Application itself, including for the prevention of fraud, of abuse, and of imminent physical harm. Material apparently relating to the sexual abuse or exploitation of a child is reported to the National Center for Missing and Exploited Children in accordance with 18 U.S.C. § 2258A, and is preserved as required by subsection (h) of that section.

Should the business be transferred in whole or in part, whether by merger, acquisition, reorganization, or sale of assets, personal information may be transferred as part of the transaction. The recipient would remain bound by the commitments contained in the Policy in respect of the information transferred, and notice of the change would be given within the Application or by electronic mail before the information became subject to a materially different notice.

Aggregated or de-identified information that cannot reasonably be used to infer the identity of any individual falls outside the restrictions described above. Where such information is used, we maintain it in de-identified form and do not attempt to re-identify it, except for the purpose of testing whether the de-identification process operates correctly.

14. Absence of sale, of sharing, and of advertising activity

Personal information is not sold, and has never been sold, within the meaning of Cal. Civ. Code § 1798.140(ad) or of any comparable state statute. Personal information is not shared for cross-context behavioral advertising within the meaning of Cal. Civ. Code § 1798.140(ah). No advertising is displayed within the Application, no advertising identifier is collected, no profile is constructed for advertising purposes, and no automated decision producing legal effects or similarly significant effects is made in respect of any user.

Sensitive personal information, comprising the commercial driver’s license number, precise geolocation, and the contents of communications in respect of which we are not the intended recipient, is used exclusively for the purposes permitted by 11 C.C.R. § 7027(m), namely the provision of the services requested by the user, the prevention of fraud and of security incidents, the safety of individuals, and compliance with legal obligations. No use is made of that information in order to infer characteristics about a user.

15. Storage locations, and international transfers

The company operating the Application is established in the Republic of Moldova, so personal information is accessible to its personnel from that country. The application backend and the database are hosted in the United States. Object storage is provided by a service with a global infrastructure. The voice server operated by us is located in the United States, and audio traffic passes through it in real time without being stored. Map tiles are supplied from infrastructure in the United States and in the European Union, and searches by place name reach infrastructure in the United Kingdom and in the European Union.

Use of the Application therefore entails the transfer of personal information across national borders, including transfers outside the country in which the user resides. Legal protections available in a receiving country may differ from those available in the country of residence. Where transfers occur, they are governed by the contractual terms agreed with each provider, by the technical measures described in Section 17, and by the limitation of each transfer to the information necessary for the function concerned.

16. Retention periods

Retention follows the principle that information is kept for as long as the account exists and the purpose persists, and is erased when neither condition holds. Periods applicable to each category are set out below, and the account deletion page repeats them in the form addressed to users.

16.1 Account, profile, and content

The account record, the profile fields, alerts, comments, votes, and chat messages are retained for as long as the account remains open. Following a request for deletion, the account is closed at once and erasure is completed within 30 days of verification of the request, while copies held in encrypted backups are overwritten in the ordinary cycle and in any event within 90 days.

16.2 Commercial driver’s license documents

Photographs of a license are erased once the verification decision has been recorded, and no later than 30 days after that decision, as described in Section 8. The outcome of the verification and the expiration date of the license are retained while the account remains open.

16.3 Location information

The single record of the last known position is overwritten at every update and is erased upon deletion of the account. No location history is created at any time. Coordinates published as part of an alert follow the retention of the alert itself.

16.4 Voice rooms and voice messages

Audio from voice rooms is not retained at any point. Metadata concerning a room is retained while the room exists, and a room without activity is deleted automatically after 15 days. Voice messages sent within a chat follow the retention applicable to chat content.

16.5 Technical and security records

Push tokens are erased when the user signs out, when the token is reported as invalid, or when the account is deleted. Session refresh tokens expire according to their own schedule and are revoked on sign-out. Records of one-time passcode requests are retained for 12 months for the prevention of fraud and abuse. Files left in object storage without an associated record are removed automatically by the lifecycle rules of the storage service.

16.6 Moderation, safety, and enforcement records

Reports, moderation decisions, and enforcement actions are retained for 24 months following the closure of the account concerned, so that repeated conduct may be identified and so that decisions may be explained if challenged. Where an account has been suspended or banned for reasons of safety, an irreversible cryptographic representation of the telephone number is retained for 12 months in order to prevent immediate re-registration, and the number itself is not preserved in a readable form.

16.7 Correspondence and legal matters

Correspondence received at our published electronic mail address is retained for 24 months from the closure of the matter. Where information is relevant to an actual or a reasonably anticipated legal claim, to an investigation, or to a specific legal obligation, retention continues for as long as the matter requires and ends when it is concluded. Material reported to the National Center for Missing and Exploited Children is preserved for the period required by 18 U.S.C. § 2258A(h), which is one year, or for longer where a competent authority so requires.

17. Security measures

Traffic between the Application and the backend travels over encrypted connections, and audio in voice rooms is encrypted in transit through DTLS-SRTP. Credentials and tokens held on the device are stored in the secure storage provided by the operating system, namely the Keychain on iOS and encrypted preferences on Android. Access to production systems is restricted to the personnel who require it, authentication of users depends on a one-time passcode delivered to the registered number rather than on a reusable password, and the rate of sign-in requests is limited in order to frustrate automated attacks. Documents relating to commercial driver’s license verification are held in a private storage area and reachable only through links that expire after 10 minutes.

No system connected to a public network can be guaranteed to be impenetrable, and no assurance to the contrary is given. Users assist materially in their own protection by keeping control of the telephone number registered, by declining to share one-time passcodes with any person, and by reporting suspicious activity to support@trucker-network.com. Where an incident affecting personal information occurs, notification is given to the individuals concerned and to the competent authorities in accordance with the applicable state breach notification statutes.

18. Rights available to every user

Independently of the state of residence, and independently of whether a particular statute applies to us, the following rights are extended to every user of the Application. A user may request confirmation of whether personal information concerning that user is processed, and may obtain access to it. A user may request the correction of information that is inaccurate or incomplete. A user may request the deletion of the account and of the information associated with it, subject to the exceptions described in Section 16. A user may request a copy of the information supplied by that user in a portable, commonly used electronic format. A user may withdraw a consent previously given, including consent to the processing of a commercial driver’s license, and may withdraw a device permission through the settings of the operating system. A user may object to a particular processing operation and ask that it be reconsidered.

No user is subjected to detriment, to a reduction in the quality of the service, or to a difference in price for having exercised any of those rights.

19. Additional provisions for residents of California

Residents of California enjoy the rights conferred by the California Consumer Privacy Act, as amended by the California Privacy Rights Act, at Cal. Civ. Code § 1798.100 and following. The disclosures below are made in order to satisfy the notice requirements of that legislation.

Categories of personal information collected in the preceding 12 months, expressed by reference to Cal. Civ. Code § 1798.140(v)(1), comprise identifiers, including the telephone number, the display name, the profile-sharing code, and the device push token; categories described at Cal. Civ. Code § 1798.80(e), including the name, the electronic mail address, and the commercial driver’s license number; professional or employment-related information, including the employer, the trailer type, the years of experience, and the status of the license; geolocation data, in the terms described in Section 7; audio, electronic, and visual information, comprising photographs, video, and voice messages; internet or other electronic network activity information limited to interactions with the Application itself; and sensitive personal information as identified below.

Sensitive personal information, within Cal. Civ. Code § 1798.140(ae), comprises the commercial driver’s license number under subparagraph (1)(A), precise geolocation under subparagraph (C), and the contents of communications in respect of which we are not the intended recipient under subparagraph (E). Use of that information is confined to the purposes permitted by 11 C.C.R. § 7027(m), as stated in Section 14, so the right to limit the use of sensitive personal information conferred by Cal. Civ. Code § 1798.121 is satisfied by the practice already in place, and no separate mechanism is required.

Sources of the information, the business and commercial purposes for which it is collected, and the categories of recipients to whom it is disclosed appear at Sections 5, 6, and 11 respectively. No category of personal information has been sold or shared in the preceding 12 months. No personal information belonging to a consumer known to be under 16 years of age has been sold or shared at any time.

A resident of California may exercise the right to know under Cal. Civ. Code §§ 1798.100, 1798.110, and 1798.115, the right to delete under Cal. Civ. Code § 1798.105, the right to correct under Cal. Civ. Code § 1798.106, the right to opt out of the sale or sharing of personal information under Cal. Civ. Code § 1798.120, which has no practical application because no such activity occurs, the right to limit the use of sensitive personal information under Cal. Civ. Code § 1798.121, and the right to be free from retaliation under Cal. Civ. Code § 1798.125.

A request may be submitted by an authorized agent acting on behalf of a consumer, in which case written authorization signed by the consumer is required, together with verification of the identity of the consumer, unless the agent produces a valid power of attorney granted under Cal. Prob. Code §§ 4121 to 4130, which 11 C.C.R. § 7063(b) treats as dispensing with that requirement. A power of attorney is never demanded as a condition of acting through an authorized agent.

As required by Cal. Bus. & Prof. Code § 22575(b)(5), the following disclosure is made regarding automated signals. The Application is a native mobile application and does not receive a Do Not Track signal of the kind transmitted by a web browser, and it performs no tracking of users across other services or applications. On the web pages published at truckers-network.com, an opt-out preference signal such as the Global Privacy Control is respected where it is received, although no sale or sharing occurs against which the signal would operate. As required by paragraph (6) of the same subdivision, we further disclose that no other party collects personally identifiable information about the online activities of a user, over time and across different websites, through the Application or through those pages.

A resident of California who is dissatisfied with our handling of a request may lodge a complaint with the California Privacy Protection Agency at https://cppa.ca.gov, or with the Office of the Attorney General of California at https://oag.ca.gov/contact/consumer-complaint-against-business-or-company.

20. Additional provisions for residents of other states

Comprehensive consumer privacy legislation is in force in a growing number of states, among them Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, and Virginia, and further statutes are due to take effect in additional states. Several of those statutes apply only to controllers that exceed thresholds of revenue or of the number of consumers whose information is processed, and we may fall below the applicable threshold in a given state. Rather than examine each threshold before answering a request, we extend the rights described in Section 18 to residents of every state of the United States, whatever the threshold position may be.

Where a statute of the state of residence confers rights beyond those described in Section 18, those additional rights are honored according to their terms. Processing of sensitive data, which in most of those statutes includes precise geolocation and information revealing a government-issued identification number, is carried out only with the consent of the consumer, obtained as described in Sections 7 and 8. Targeted advertising, the sale of personal data, and profiling producing legal or similarly significant effects are not carried out, so no opt-out mechanism is required in respect of them.

A consumer whose request is refused may appeal by writing to support@trucker-network.com with the word "Appeal" in the subject line. An appeal is decided within 45 days of receipt, and the decision is communicated in writing together with the reasons for it. Where an appeal is refused, the consumer is informed of the means by which a complaint may be submitted to the Attorney General of the state of residence.

21. Submitting a request, and verification of the person submitting it

A request may be submitted from within the Application, where the relevant functions appear in the account settings, or by writing to support@trucker-network.com. A request concerning the deletion of an account may also be submitted through the page published at https://truckers-network.com/account/delete, which remains available to a person who has already uninstalled the Application.

Verification is necessary before information is disclosed or erased, and it is conducted in the least intrusive manner available. In the ordinary case, verification is achieved by confirming control of the mobile telephone number registered with the account, either through a one-time passcode or through a request sent from the electronic mail address recorded in the profile. Additional information is requested only where the request concerns sensitive personal information or where the circumstances give rise to doubt, and any information supplied for the purpose of verification is used for that purpose alone and is then erased.

Acknowledgment is sent within 10 business days of receipt. A substantive response follows within 45 days, extendable once by a further 45 days where the complexity or the number of requests requires it, in which case notice of the extension and of the reason for it is given within the initial period. No charge is made for a request, unless it is manifestly unfounded or excessive, in which case a reasonable fee may be charged or the request may be refused, and the reasons are stated in writing.

22. Consent, and the withdrawal of consent

Consent operates at several distinct points, and each may be withdrawn independently of the others. Permission to access the camera, the microphone, the photograph library, and location is granted through the operating system and may be revoked at any moment in its settings, whereupon the corresponding function ceases. Consent to the processing of a commercial driver’s license is given expressly in the verification flow and may be withdrawn by writing to support@trucker-network.com, which results in the erasure of the documents and the removal of the verified status.

Consent to receive push notifications is granted through the operating system and may be withdrawn there or in the settings of the Application. Consent to receive one-time passcodes by short message is inherent in the act of registering and signing in, and it is withdrawn by ceasing to use the Application and requesting the deletion of the account. Withdrawal of consent operates for the future and does not affect the lawfulness of processing carried out before it.

23. Deletion of the account

An account may be deleted from within the Application, in the account settings, and the operation removes the account record together with the personal information associated with it, subject to the limited exceptions set out in Section 16. A person who has already uninstalled the Application, and who therefore cannot reach the in-app function, may request deletion through the page published at https://truckers-network.com/account/delete or by writing to support@trucker-network.com from the electronic mail address recorded in the profile, stating the mobile telephone number registered with the account.

The page identified above sets out what is erased, what is preserved, the reasons for preservation, and the applicable periods, and it forms part of the disclosures made by the Policy.

24. Amendments to the Policy

The Policy may be amended in order to reflect a change in the Application, in the providers engaged, or in the applicable law. The date of the most recent amendment appears at the head of the document. Where an amendment is material, notice is given within the Application before it takes effect, and, where the law requires it, consent is obtained afresh. Continued use of the Application after an amendment has taken effect constitutes acceptance of the amended text, and a user who does not accept it may delete the account by the means described in Section 23. Previous versions are supplied on request to support@trucker-network.com.

25. How to contact us

Truckly Network, Str. Puskin 32, Chisinau, Republic of Moldova. General assistance, privacy requests and complaints, and reports concerning content, abuse, or the safety of a minor: support@trucker-network.com. Account deletion: https://truckers-network.com/account/delete.