IRON SHEEPDOG PRIVACY POLICY

Iron Sheepdog Holdings, Inc., a Virginia corporation (“Iron Sheepdog,” “we,” “us” or “our”) provides an online and mobile platform (the “Iron Sheepdog Platform”) provides a marketplace where customers seeking transportation of loads and other jobs to be completed (“Companies”) can be matched with transportation service brokers (“Brokers”) for contracts to complete the listed jobs, and where Brokers can contract with individual persons or companies who provide actual transportation services with respect to those jobs (“Operators”). Companies, Brokers and Operators are collectively referred to herein as “Users.”

SMS/MMS Messaging Consent and Compliance (A2P Section)

A2P Compliance

• Our messaging practices are rigorously aligned with A2P compliance standards, ensuring lawful and responsible use of SMS/MMS messaging.

Data Usage

• We use personal data primarily for user account management, service improvement, and relevant communication (offers, updates), as per A2P guidelines.

Consent for SMS/MMS Communication

• By providing your phone number, you consent to receive A2P compliant SMS/MMS messages from Iron Sheepdog, including service updates, transactional information, and promotional content.

Opt-In and Opt-Out Procedures

• To receive messages, opt-in by providing your phone number via our platform with “START” or “SUBSCRIBE”. Opt-out at any time by texting “STOP”, following which you will receive a confirmation of unsubscription, in line with A2P requirements.

Message Types and Frequency

• Messages, including service notifications, transaction updates, and marketing messages, adhere to A2P standards. Frequency is controlled and will not exceed one message per day.

Message and Data Rates

• Standard message and data rates apply, consistent with A2P messaging guidelines.

Age Restriction

• In compliance with A2P regulations, we do not solicit personal information via SMS/MMS from individuals under the age of 18.

Data Security

• We ensure the security of personal information received through SMS/MMS, protecting it against unauthorized access or misuse, in accordance with A2P and CTIA standards.

Automated Systems and Third-Party Providers

• Some messages are sent using automated systems. Third-party providers engaged in messaging are bound by confidentiality and A2P compliance requirements.

Legal Compliance and Updates

• Our messaging is in strict compliance with telecommunications and data privacy laws, and we regularly update our practices to maintain A2P compliance.

CTIA Guidelines Alignment

• Alongside A2P, we align with CTIA guidelines, emphasizing user privacy, clear communication, and maintaining transparency in our data practices, thereby upholding consumer consent and the integrity of personal information.

Contact and Governing Law

• For queries, contact us at support@isheepdog.com. This policy is governed by Virginia law, under the jurisdiction of courts in Williamsburg, VA.

This Privacy Policy describes how Iron Sheepdog collects, uses, and discloses information when you use the Iron Sheepdog Platform, contract for services (“Services”) within the Iron Sheepdog Platform, or when you otherwise interact with us.

We may change this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of the policy and, in some cases, we may provide you with additional notice (such as adding a statement to our homepage or sending you a notification). We encourage you to review the Privacy Policy whenever you access the Iron Sheepdog Platform or otherwise interact with us to stay informed about our information practices and the choices available to you.

Information You Provide to Us

We collect information you provide directly to us. For example, we collect information when you fill out a form, request to be a Company, Broker, or Operator, log into your Iron Sheepdog account, submit or accept a request for Services, request customer support, or otherwise communicate with us. This information may include name, company name, email address, phone number, government identification numbers, financial information, insurance information, vehicle information, service ratings and reviews, and any other information you choose to provide. In certain cases, for the safety of all Users, we may also perform background checks which may include driving records or criminal records (where permitted by law). We may also collect demographic information about you, including through User surveys.

Information We Collect When You Use the Services

When you use the Iron Sheepdog Platform, we collect additional information about all relevant Services and how they are performed, including the following:

• Companies: If you are a Company and submitting a Service request, we collect certain details related to your submission, including the date and time of your request, origin and destination addresses, description of the cargo being transported, rate, and other information about such Services.
• Brokers: If you are a Broker, we collect information on your bids on Service requests as well as information about your acceptance and fulfillment of any Service requests, including vehicle and Operator information.
• Operators: If you are an Operator transporting cargo on behalf of a Broker, we may collect information on your travel to fulfill a Service request and information regarding your performance of the Services. We also collect information about your location and about files you upload as described below.
• Users Generally: In all cases we collect information on the transactions of Services, including the type of Services requested or provided, details as to the provision and delivery of such Services, dates and times such Services were provided, the amounts charged, details on the negotiations of amounts charged, distances traveled, and routes taken.

Location Information

Providing Services to our Users requires the collection of precise location information. When you download and use our mobile applications, we will ask for permission to access your precise location. If you grant our mobile applications permission to access your location through the permission system used by your mobile operating system, we will collect the precise location of your device. We use this information to track Services, and to understand Operators’ typical driving patterns so as to offer Brokers jobs that are more likely to be relevant to them and their Operators. We may also derive your approximate location from your IP address or phone number. We may also receive information about your location from third parties, such as the Companies and Brokers involved in fulfilling any Service request.

Photos

Our Services may ask you to photograph and upload to the Iron Sheepdog Platform certain documents related to the fulfillment of a Service request, such as certificates of insurance or other legal documents, bills of lading, and proofs of delivery. You may also be able to upload pictures of cargo involved in the Services. To do this, our mobile applications will request access to the camera on your device via the permission system used by your mobile operating system.

Information We Collect Automatically When You Use the Iron Sheepdog Platform

When you access or use the Iron Sheepdog Platform, we automatically collect information about you, including:

• Usage & Log Information: We collect information about how you interact with the Iron Sheepdog Platform. This includes information such as access dates and times, app features or pages viewed, app crashes and other system activity, type of browser, IP addresses, 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.
• Device Information: We collect information about the computer or mobile device you use to access our Services, including the hardware model, operating system and version, device and app identifiers, and mobile network information.
• Information Collected by Cookies and Other Tracking Technologies: We use various technologies to collect information, including cookies and web beacons. Cookies are small data files stored on your hard drive or in device memory that help us improve our Services and your experience, see which areas and features of our Services are popular, and count visits. Web beacons are electronic images that may be used in our Services or emails and help deliver cookies, count visits, and understand usage and campaign effectiveness. For more information about cookies, and how to disable them, please see “Advertising and Analytics Services Provided by Others” below.

Information We Collect from Other Sources

We may also obtain information from other sources and combine that with information we collect directly. These third parties include, but are not limited to, verification services (for instance, to confirm your insurance or regulatory compliance status), credit bureaus, and publicly available sources.

We use the information we collect to provide and improve our Services, including to connect Companies with Brokers, match Operators with requests for Services, facilitate transportation of cargo, provide payments, and confirm delivery. We use your phone number to call you and send you SMS messages about potential and current Services. We may also use information about you for other purposes, including to:

• Send you technical notices, updates, security alerts and support, and administrative messages;
• Respond to your comments, questions, and requests and provide customer service;
• Communicate with you about products, services, offers, opportunities, promotions, rewards, and events offered by Iron Sheepdog and others, and provide news and information we think will be of interest to you;
• Monitor and analyze trends, usage, and activities regarding our Services;
• Detect, investigate, and prevent fraudulent transactions and other illegal activities and protect the rights and property of Iron Sheepdog and others;
• Personalize and improve the Iron Sheepdog Platform and Services provided, and any advertisements, content, or features that match user profiles or interests;
• Link or combine with information we get from others to help understand your needs and provide you with better service; and
• Carry out any other purpose described to you at the time the information was collected.

Advertising and Analytics Services Provided by Others

We may allow others to provide analytics services and serve advertisements on our behalf across the internet and in applications. These entities may use cookies, web beacons, device identifiers, and other technologies to collect information about your use of the Iron Sheepdog Platform and other websites and applications, including your IP address, web browser, mobile network information, pages viewed, time spent on pages or in apps, links clicked, and conversion information. This information may be used by Iron Sheepdog and others to, among other things, analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests on our Services and other websites, and better understand your online activity. For more information about interest-based ads, or to opt out of having your web browsing information used for behavioral advertising purposes, please visit www.aboutads.info/choices. Your device may also include a feature (“Limit Ad Tracking” on iOS or “Opt Out of Interest- Based Ads” on Android) that allows you to opt out of having certain information collected through apps used for behavioral advertising purposes.

Security

Iron Sheepdog takes reasonable measures to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration, and destruction.

General Contact Information

Address: 123 Bulifants Blvd Suite B, Williamsburg, VA 23188

Email: support@isheepdog.com