Privacy Policy-Carrier

Privacy Policy-DalabMart Carrier

Last updated: October 15, 2024

1. About DalabMart Carrier and this Privacy Policy.

DalabMart LLC, and its group companies (collectively, “DalabMart,” “we,” “us,” or “our”) are committed to protecting your privacy. DalabMart is a technology company that connects people with the best of their neighborhoods by enabling local businesses to meet consumers’ needs of ease and convenience, and, in turn, generate new ways for people to earn, work, and live. This Privacy Policy (“Policy”) explains how we process personal information from, of, or about: (1) individuals who have signed up, as independent contractors, to be drivers and to perform other tasks, including, without limitation, those who are considered to be runners or other similar references (“DalabMart Carrier(s)”) as part of the Dalabmart Carrier Services (as defined below); and (2) a limited group of “Non-DalabMart Carriers”: (a) the emergency contacts of DalabMart Carriers, (b) individuals whose personal information is processed in connection with referral communications created and initiated by DalabMart Carriers (“Referral(s)”), and (c) individuals who visit or access our Dalabmart Carrier platforms (e.g., apps, websites, etc.) but who are not DalabMart Carriers. When we are processing personal information in the role or capacity of a processor, DalabMart’s processing is subject to the instructions received by DalabMart from the appropriate Controller, in which case this Policy will not apply. The term “Controller” means the natural or legal person that, alone or jointly with others, determines the purposes and means of processing personal information. The term “DalabMart Carrier Services” means the services and activities for DalabMart Carriers available on or through https://dalabmart.com/dalabmart-carrier-apply/, the Dalabmart Carrier mobile application, and any other website or mobile application that links to this Policy, as well as during any written, electronic, and oral communications relating to the Dalabmart Carrier Services and the individuals whose personal information is covered under or by this Policy.

If you are a Dalabmart Carrier your access to and use of the Dalabmart Carrier Services are subject to our Independent Contractor Agreement (“ICA”) Please make sure that you have carefully read and understood the ICA before you use the Dalabmart Carrier Services. By using the Dalabmart Carrier Services, you accept the ICA, and accept our privacy practices described in this Policy. If you do not feel comfortable with any part of this Policy or our ICA, you must not use or access the Dalabmart Carrier Services.

This Policy does not apply to our processing of your personal information as a consumer. Our consumer privacy policy is available here.

Please note that if you submit or upload personal information for, of, or about another person (e.g., in connection with a Referral, adding an emergency contact, etc.), by submitting or uploading the personal information to us or the Dalabmart Carrier Services you hereby certify that you have the consent or approval of the other person(s) for DalabMart and you to process the personal information in connection with the purpose(s) for which you submitted or uploaded the personal information, including, without limitation, in connection with the transmission of communications (e.g., via SMS/text messages, email, phone, etc.) by or from you and DalabMart to the other person(s).

2. Processing Activities.

A. DalabMart Carriers.

In connection with the Dalabmart Carrier Services, DalabMart processes personal information from, of, or about DalabMart Carriers in the context of their engagement as independent contractors for DalabMart. In connection with the Dalabmart Carrier Services, which are called contracted services in the ICA, DalabMart Carriers can complete tasks and other activities.

(a) Notice at Collection.

(1) The Categories of Personal Information that We May Collect.

(A) Identifiers: Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, phone number, account name, social security number, driver’s license number, passport number, license plate number, or other similar identifiers.

(B) Additional Information: any additional personal information such as signature, physical characteristics or description, state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, bank account routing number, or any other financial information, medical information, or health insurance information.

(C) Identification Documentation: such as drivers’ license, passport, state identification card, and other similar identification documents that are used for verification purposes (e.g., age verification to be a Dalabmart Carrier or to make certain tasks.

(D) Protected Classifications: Characteristics of protected classifications under applicable state (e.g., California) or federal law, such as race, color, national origin, religion, age, sex, gender, gender identity, gender expression, sexual orientation, marital status, medical condition, ancestry, disability, citizenship status, and military and veteran status.

(E) Online Activity: Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with an internet website application, or advertisement.

(F) Geolocation Data: Data that is derived from a device and is used or intended to locate an individual within a geographic area.

(G) Sensory Information: Audio, electronic, visual, thermal, olfactory, or similar information, such as pictures, videos, audio recordings, etc.

(H) Inferences Information: Inferences drawn from any of the information identified in this subdivision to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

(I) Sensitive Personal Information: as these terms are defined under applicable data protection and privacy laws, including precise geolocation (see below for further information); a social security, driver’s license, state identification card, or passport number; racial or ethnic origin; religious beliefs; mental or physical health diagnosis; sex life or sexual orientation; or citizenship; etc. We do not use or disclose your sensitive data or sensitive personal information for purposes other than to perform the services reasonably expected by an average user, for security and legal reasons, with your consent, and/or for other purposes permitted by applicable law.

(J) Communications Data: Such as the nature and content of communications, date and time sent, etc.

(K) Survey Response Data: Such as demographic information and survey responses that you provide when you voluntarily participate in a survey for us.

(L) Preferences Information: Such as language preferences, preferred region, communication preferences, delivery preferences, etc.

(M) Dalabmart Carrier Services Information: Information related to your use of, and your activities in connection with, the Dalabmart Carrier Services, including customer reviews, task information (e.g., number of tasks accepted, number of tasks declined, delivery route information, time to complete tasks, number of tasks completed, etc.), payment amounts for each task, tip amounts, attribution and conversion path, etc.

(N) Verification Check Information: includes all information returned to DalabMart when conducting checks on potential and actual DalabMart Carriers, including background, vehicle registration, driving history, insurance verification checks, etc.

(O) Information Collected from Devices: includes information such as magnetometer and pedometer data collected for product improvement purposes, specifically for purposes like in-store navigation.

(2) The Business and Commercial Purposes for Which Personal Information May Be Processed. DalabMart may process, and share with the categories of parties identified in Section 2.A.(b)(2) of this Policy, your personal information for the purposes set forth below.

1. Identifiers, Additional Information, Identification Documentation, Online Activity, Sensory Information, Sensitive Personal Information, Preferences Information, Verification Check Information:

Onboarding you as a Dalabmart Carrier, such as conducting certain checks (e.g., background, vehicle registration, insurance and driving history checks, etc.), verifying your age for qualifying to be a Dalabmart Carrier, creating your account with the Dalabmart Carrier Services, setting up direct deposit, etc.

2. Identifiers, Additional Information, DalabMart Services Information:

Administering payments to you for participation in the Dalabmart Carrier Services, such as processing payments, including, without limitation, payment of tips, payment for each task, for each qualifying activity in connection with the Dalabmart Carrier Services, including payments to DalabMart’s red card and payments through your financial accounts.

3. Identifiers, Additional Information, Identification Documentation, Online Activity, Geolocation Data, Sensitive Personal Information, Preference Information, Information Collected From Devices, Dalabmart Carrier Services Information:

Operating and administering the Dalabmart Carrier Services, such as assessing, tracking, and reporting on a DalabMart Carrier’s tasks and activities in connection with the Dalabmart Carrier Services, including offer acceptances and declinations and acceptance and cancellation rates; tracking the number of tasks that a Dalabmart Carrier makes; the date and time of offer acceptances, declinations, cancellations, pick-ups and completions; time to complete tasks; delivery route information; the number of deliveries per task; customer ratings and other feedback; payment amounts; attribution and user conversion path; etc.

4. Identifiers, Communications Data, Dalabmart Carrier Services Information:

Administering our Referral programs, such as setting up Referrals, transmitting Referral communications initiated by a Dalabmart Carrier, tracking completion of tasks related to Dalabmart Carrier Services, etc.

5. Identifiers, Geolocation Data:

Location Tracking, we require location tracking for Dalabmart Carrier using the Dalabmart Carrier application, which may collect and process location information in the foreground and background of your device and from any photos that you provide to us. Location tracking is used to verify route information, qualify you for delivery opportunities in your area, and track your progress on a task(s) (e.g., when an order was picked up and when it was delivered).

6. Identifiers, Dalabmart Carrier Services Information, Protected Classifications, Inferences Information:

To qualify you for, and to administer your participation in, opportunities with our business partners

7. Identifiers, Communications Data, Dalabmart Carrier Services Information:

Communications purposes, such as (i) sending you transactional, informational and/or marketing communications via SMS/text messages, telephone calls, email, push notifications and/or through other channels/methods; (ii) if you contact us, we will use your personal information in responding to your questions or assisting with any issues raised in connection with the Dalabmart Carrier Services (including the content and/or materials that you provide, which will be treated as your non-confidential and non-proprietary information) and in taking actions as a result of the communications; and (iii) reviewing, storing, and/or monitoring communications between you and any DalabMart user/customer or merchant arising in connection with the Dalabmart Carrier Services for complying with legal and regulatory requirements; protecting people, property and interests of DalabMart, DalabMart personnel, users/customers, you, DalabMart Carriers, and other persons and people; enforcing the terms and conditions between you and DalabMart; fraud detection and prevention and security purposes; assessing your performance in connection with the Dalabmart Carrier Services for assessment, evaluation, quality control and training purposes.

8. Identifiers, Communications Data, Dalabmart Carrier Services Information:

9. Identifiers, Online Activity, Dalabmart Carrier Services Information:

Engage in marketing activities in connection with cookies and similar technologies as described in Section 3 of this Policy

Providing advertising and marketing services, except for cross-context behavioral advertising, to you provided that, for the purpose of advertising and marketing, a service provider or contractor shall not combine the personal information of opted-out consumers that the service provider or contractor receives from, or on behalf of, DalabMart with personal information that the service provider or contractor receives from, or on behalf of, another person or persons or collects from its own interaction with consumers

10. Identifiers, Additional Information, Identification Documentation, Protected Classifications, Online Activity, Geolocation Data, Sensory Information, Inferences Information, Sensitive Personal Information, Communications Data, Survey Response Data, Preferences Information, Information Collected from Devices, Dalabmart Carrier Services Information, Verification Check Information:

Administering your Dalabmart Carrier relationship with DalabMart

Performing services on behalf of DalabMart and operating and administering DalabMart’s business, the Dalabmart Carrier Services and our platforms, such as maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, processing payments, personalizing the Dalabmart Carrier Services and our platforms; creating, enhancing, and optimizing the Dalabmart Carrier Services and our platforms; complying with internal policies and processes and internal and external audit requirements; performing assessments and analytics; improving offerings to DalabMart Carriers; undertaking internal research for technological development and demonstration; and engaging in other activities and services on behalf of DalabMart

To comply with applicable laws, codes and regulations

To enforce the terms and conditions (i.e., the ICA) and/or other agreements between you and DalabMart

To handle enquiries, complaints, and requests

Exercising our rights and defending ourselves from claims

Protecting the interests, rights, and property of DalabMart Carriers, DalabMart, DalabMart’s personnel, you and other persons and parties

To monitor, investigate, prevent, mitigate, remediate, and report any alleged or actual prohibited, illicit, or illegal activities

Helping to ensure security and integrity to the extent the use of your personal information is reasonably necessary and proportionate for these purposes

Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by DalabMart, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by DalabMart

11. Identifiers, Protected Classifications, Online Activity, Geolocation Data, Sensory Information, Inferences Information, Sensitive Personal Information, Communications Data, Dalabmart Carrier Services Information:

To qualify you for, to contact you to participate in, and to conduct, survey research activities

12. Identifiers, Online Activity, Geolocation Data, Sensitive Personal Information:

Short-term, transient use, including, but not limited to, non-personalized advertising shown as part of a consumer’s current interaction with DalabMart, provided that the consumer’s personal information is not disclosed to another third party and is not used to build a profile about the consumer or otherwise alter the consumer’s experience outside the current interaction with DalabMart

13. Identifiers , Additional Information , Online Activity , Geolocation Data , Sensory Information , Inferences Information , Sensitive Personal Information , Communications Data , Survey Response Data , Information Collected from Devices , Preferences Information , Dalabmart Carrier Services Information:

Debugging to identify and repair errors that impair existing intended functionality.

14. Identifiers, Online Activity:

Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards

(3) Retention of Personal Information. For the categories of personal information collected, the personal information is retained in accordance with Section 5 of this Policy.

(4) Categories of Personal Information that We May Sell or Share (as these terms are defined under applicable data protection and privacy laws) and the Purpose(s) for Which the Personal Information May be Sold or Shared

Categories of Parties

Categories of Personal Information

Purposes

Advertising Partners

Analytics Providers

Media Companies (those performing cross-context behavioral advertising on behalf of DalabMart

Identifiers

Dalabmart Carrier Services Information Online Activity

Providing marketing and advertising services for the benefit of DalabMart and the Dalabmart Carrier Services

Engaging in Cross-context behavioral advertising on behalf of and for DalabMart

(b) Prior Collection, Use and Disclosure of Personal Information.

We may have collected and processed (e.g., used, shared, etc.) your personal information, as described in Section 2.A.(a) of this Policy, during the preceding 12 months. For the personal information collected during this period, we describe below: (1) the categories of sources from which we have collected the personal information, (2) the categories of parties with whom we have disclosed your personal information for our business or commercial purposes, and (3) the categories of personal information we have disclosed for a business purpose.

(1) Categories of Sources From Which We Have Collected the Personal Information.

1. Identifiers , Additional Information , Identification Documentation , Protected Classifications , Sensory Information , Sensitive Personal Information , Communications Data , Survey Response Data , Preferences Information , Dalabmart Carrier Services Information:

Information you provide to us directly , such as when registering for and using the Dalabmart Carrier Services; communicating with us; performing tasks, actions or activities as a Dalabmart Carrier; etc.

2. Identifiers, Communications Data:

Information received as part of communications, such as when you communicate with us, with a user/customer, or a merchant

3. Identifiers, Online Activity, Geolocation Data, Information Collected from Devices:

Information collected automatically from your device, browser, or system, such as through cookies and similar technologies as described in Section 3 of this Policy

4. Identifiers:

Information collected in connection with a Referral

5. Identifiers, Online Activity:

Information collected from linked social networks, when you link your social networks to your account with the Dalabmart Carrier Services

6. Identifiers, Protected Classifications, Online Activity, Inferences Information:

Information collected from market enrichment partners, such as when we acquire additional information about you from third parties

Information collected from advertising partners and analytics providers, such as in connection with our marketing campaigns

7. Identifiers, Additional Information, Protected Classifications, Inferences Information, Sensitive Personal Information:

Information collected from business partners, such as when you voluntarily participate in a partnership or product offering

8. Identifiers, DalabMart Carrier Services Information:

Information collected from users/customers, such as when we receive feedback/reviews or communications from users/customers in connection with your tasks and activities as a Dalabmart Carrier.

Information collected from merchants, such as when we receive feedback/reviews or communications from merchants in connection with your tasks and activities as a Dalabmart Carrier.

9. Identifiers, Additional Information:

Information collected from payment providers, such as when we process payments to you

10. Verification Check Information:

Information collected from third parties in connection with a background and vehicle and driver history check.

(2) Categories of Parties with Whom We Have Disclosed the Personal Information for our Business or Commercial Purposes.

1. Identifiers , Additional Information , Identification Documentation , Protected Classifications , Online Activity , Geolocation Data , Sensory Information , Inferences Information , Sensitive Personal Information , Communications Data , Survey Response Data , Preferences Information , Information Collected from Devices , Dalabmart Carrier Services Information , Verification Check Information:

Our affiliates

Vendors providing services to us or on our behalf

Professional services organizations (e.g., legal professionals, accountants, auditors, etc.)

Any entity, agency, department, authority or other body that we have an obligation, duty, or are otherwise permitted or required to disclose your personal information to (e.g., regulators, government authorities, law enforcement, courts, etc.)

Third parties in order to participate in, or be the subject of, any sale, merger, acquisition, restructure, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock or other similar transaction(s), in which case we may disclose your personal information to prospective buyers, sellers, advisers or partners and your data may be a transferred asset in a business sale

Persons or parties that you instruct or direct us, or provide consent for us, to disclose your personal information to Third parties as required or permitted to comply with legal and/or regulatory requirements and obligations

Parties in connection with legal proceedings

2. Identifiers, Geolocation data (through maps functionality):

Merchants, such as when you are picking up an order for delivery

Users/customers, such as when you are delivering an order to a user/customer

3. Identifiers, DalabMart Carrier Services Information:

Social networks, such as when you link your Dalabmart Carrier account with a social network.

4. Identifiers, Inferences Information, Sensitive personal information, Communications Data, Preferences Information, Dalabmart Carrier Services Information:

Business partners, such as when you participate in product and partnership opportunities

5. Identifiers, Additional Information, Sensitive Personal Information:

Third parties for the performance of conducting checks (e.g., background, vehicle registration, driving history, insurance verification checks, etc.)

(3) Categories of Personal Information We Have Disclosed for a Business Purpose.

Please see the categories of personal information disclosed in Section 2.A.(a)(1) of this Policy.

B. Non-Dalabmart Carrier.

In connection with the Dalabmart Carrier Services, we may process personal information from, of, or about individuals other than DalabMart Carriers, including, individuals who are listed as emergency contacts of DalabMart Carriers, individuals who are referred by DalabMart Carriers for opportunities to participate in DalabMart’s business activities (including the Dalabmart Carrier Services) and individuals who visit our Dalabmart Carrier platforms. For more information, please see the following:

(a) Notice at Collection.

(1) The Categories of Personal Information that We May Collect.

(A) Identifiers

(B) Communications Data

2) The Business and Commercial Purposes for Which Personal Information May Be Processed. DalabMart may process, and share with the categories of parties identified in Section 2.B.(b)(2) of this Policy, your personal information for the purposes set forth below.

Purposes	Categories of Personal Information
For emergency contacts, we process your personal information for purposes such as contacting you in the event of an emergency situation with a Dalabmart Carrier and we cannot contact the Dalabmart Carrier or we feel it is reasonable and appropriate for us to contact you about the emergency; complying with applicable laws, codes and regulations; etc.	Identifiers Communications Data
For referred individuals, as applicable, we process your personal information for purposes such as facilitating a communication from the Dalabmart Carrier to you for the purposes of the Referral, tracking the communication and the participation of both you and the Dalabmart Carrier in connection with the applicable Referral program, communicating with you about any questions or issues relating to the Referral; complying with applicable laws, codes and regulations; etc.	Identifiers Communications Data
For website visitors, we process your personal information for the purposes of engaging in marketing and advertising activities (e.g., re-targeting); operating our platforms; administering our business activities; complying with applicable laws, codes and regulations; developing, improving, and enhancing our platforms; maintaining and enhancing the security and integrity of our platforms; etc.	Identifiers Online Activity
Helping to ensure security and integrity to the extent the use of the consumer’s personal information is reasonably necessary and proportionate for these purposes Debugging to identify and repair errors that impair existing intended functionality Performing services on behalf of DalabMart, including maintaining or servicing accounts; providing customer service; processing or fulfilling orders and transactions; verifying customer information; processing payments; providing financing; providing analytic services; providing storage; undertaking internal research for technological development and demonstration; complying with internal policies and processes and internal and external audit requirements; performing assessments and analytics; and engaging in other activities and services on behalf of DalabMart Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by DalabMart, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by DalabMart To handle enquiries, complaints, and requests Exercising our rights and defending ourselves from claims Protecting the interests, rights, and property of Dalabmart Carrier, DalabMart, DalabMart’s personnel, you and other persons and parties To monitor, investigate, prevent, mitigate, remediate, and report any alleged or actual prohibited, illicit, or illegal activities To comply with applicable laws, codes and regulations	Identifiers Communication Data Online Activity

(3) Retention of Personal Information. For the categories of personal information collected, the personal information is retained in accordance with Section 5 of this Policy.

(4) Selling or Sharing Personal Information. We do not believe that we are selling or sharing, as these terms are defined under applicable data protection and privacy laws, personal information for these categories of data subjects.

(b) Prior Collection, Use and Disclosure of Personal Information.

We may have collected and processed (e.g., used, shared, etc.) your personal information, as described in Section 2.B.(a) of this Policy, during the preceding 12 months. For the personal information collected during this period, we describe below: (1) the categories of sources from which we have collected the personal information, (2) the categories of parties with whom we have disclosed your personal information for our business or commercial purposes, and (3) the categories of personal information we have disclosed for a business purpose.

(1) Categories of Sources From Which We Have Collected the Personal Information.

Categories of Sources	Categories of Personal Information
Information you provide to us directly , such as when registering for and using the Dalabmart Carrier Services; communicating with us; performing tasks, actions or activities as a Dalabmart Carrier; etc.	Identifiers Additional Information Identification Documentation Protected Classifications Sensory Information Sensitive Personal Information Communications Data Survey Response Data Preferences Information Dalabmart Carrier Services Information
Information received as part of communications, such as when you communicate with us, with a user/customer, or a merchant	Identifiers Communications Data
Information collected automatically from your device, browser, or system, such as through cookies and similar technologies as described in Section 3 of this Policy	Identifiers Online Activity Geolocation Data Information Collected from Devices
Information collected in connection with a Referral	Identifiers
Information collected from linked social networks, when you link your social networks to your account with the Dalabmart Carrier Services	Identifiers Online Activity
Information collected from market enrichment partners, such as when we acquire additional information about you from third parties Information collected from advertising partners and analytics providers, such as in connection with our marketing campaigns	Identifiers Protected Classifications Online Activity Inferences Information
Information collected from business partners, such as when you voluntarily participate in a partnership or product offering	Identifiers Additional Information Protected Classifications Inferences Information Sensitive Personal Information
Information collected from users/customers, such as when we receive feedback/reviews or communications from users/customers in connection with your tasks and activities as a Dalabmart Carrier Information collected from merchants, such as when we receive feedback/reviews or communications from merchants in connection with your tasks and activities as a Dalabmart Carrier	Identifiers Dalabmart Carrier Services Information
Information collected from payment providers, such as when we process payments to you	Identifiers Additional Information
Information collected from third parties in connection with a background and vehicle and driver history check	Verification Check Information

(2) Categories of Parties with Whom We Have Disclosed the Personal Information for our Business or Commercial Purposes.

Categories of Parties

Categories of Personal Information

Our affiliates

Vendors providing services to us or on our behalf

Professional services organizations (e.g., legal professionals, accountants, auditors, etc.)

Persons or parties that you instruct or direct us, or provide consent for us, to disclose your personal information to

Third parties as required or permitted to comply with legal and/or regulatory requirements and obligations

Parties in connection with legal proceedings

Identifiers

Additional Information

Identification Documentation

Protected Classifications

Online Activity

Geolocation Data

Sensory Information

Inferences Information

Sensitive Personal Information

Communications Data

Survey Response Data

Preferences Information

Information Collected from Devices

Dalabmart Carrier Services Information

Verification Check Information

Merchants, such as when you are picking up an order for delivery

Users/customers, such as when you are delivering an order to a user/customer

Identifiers

Geolocation data (through maps functionality)

Social networks, such as when you link your Dalabmart Carrier account with a social network

Identifiers

Dalabmart Carrier Services Information

Business partners, such as when you participate in product and partnership opportunities

Identifiers

Inferences Information

Sensitive personal information

Communications Data

Preferences Information

Dalabmart Carrier Services Information

Third parties for the performance of conducting checks (e.g., background, vehicle registration, driving history, insurance verification checks, etc.)

Identifiers

Additional Information

Sensitive Personal Information

(3) Categories of Personal Information We Have Disclosed for a Business Purpose.

Please see the categories of personal information disclosed in Section 2.A.(a)(1) of this Policy.

B. Non-DalabMart Carriers.

In connection with the Dalabmart Carrier Services, we may process personal information from, of, or about individuals other than DalabMart Carriers, including, individuals who are listed as emergency contacts of DalabMart Carriers, individuals who are referred by DalabMart Carriers for opportunities to participate in Dalabmart Carrier’s business activities (including the Dalabmart Carrier Services) and individuals who visit our Dalabmart Carrier platforms. For more information, please see the following:

(a) Notice at Collection.

(1) The Categories of Personal Information that We May Collect.

(A) Identifiers

(B) Communications Data

(2) The Business and Commercial Purposes for Which Personal Information May Be Processed. Dalabmart Carrier may process, and share with the categories of parties identified in Section 2.B.(b)(2) of this Policy, your personal information for the purposes set forth below.

Purposes	Categories of Personal Information
For emergency contacts, we process your personal information for purposes such as contacting you in the event of an emergency situation with a Dalabmart Carrier and we cannot contact the Dalabmart Carrier or we feel it is reasonable and appropriate for us to contact you about the emergency; complying with applicable laws, codes and regulations; etc.	Identifiers Communications Data
For referred individuals, as applicable, we process your personal information for purposes such as facilitating a communication from the Dalabmart Carrier to you for the purposes of the Referral, tracking the communication and the participation of both you and the Dalabmart Carrier in connection with the applicable Referral program, communicating with you about any questions or issues relating to the Referral; complying with applicable laws, codes and regulations; etc.	Identifiers Communications Data
For website visitors, we process your personal information for the purposes of engaging in marketing and advertising activities (e.g., re-targeting); operating our platforms; administering our business activities; complying with applicable laws, codes and regulations; developing, improving, and enhancing our platforms; maintaining and enhancing the security and integrity of our platforms; etc.	Identifiers Online Activity
Helping to ensure security and integrity to the extent the use of the consumer’s personal information is reasonably necessary and proportionate for these purposes Debugging to identify and repair errors that impair existing intended functionality Performing services on behalf of DalabMart, including maintaining or servicing accounts; providing customer service; processing or fulfilling orders and transactions; verifying customer information; processing payments; providing financing; providing analytic services; providing storage; undertaking internal research for technological development and demonstration; complying with internal policies and processes and internal and external audit requirements; performing assessments and analytics; and engaging in other activities and services on behalf of DalabMart Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by DalabMart, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by DalabMart To handle enquiries, complaints, and requests Exercising our rights and defending ourselves from claims Protecting the interests, rights, and property of DalabMart Carriers, DalabMart, DalabMart ‘s personnel, you and other persons and parties To monitor, investigate, prevent, mitigate, remediate, and report any alleged or actual prohibited, illicit, or illegal activities To comply with applicable laws, codes and regulations	Identifiers Communication Data Online Activity

(3) Retention of Personal Information. For the categories of personal information collected, the personal information is retained in accordance with Section 5 of this Policy.

(b) Prior Collection, Use and Disclosure of Personal Information.

(1) Categories of Sources From Which We Have Collected the Personal Information.

Categories of Sources	Categories of Personal Information
A Dalabmart Carrier, such as when they provide your personal information as an emergency contact or when they provide your personal information for a Referral	Identifiers
You, such as when you communicate with us	Identifiers Communications Data
Information collected automatically from your device, browser, or system, such as when you access and interact with our Dalabmart Carrier platforms, such as through cookies and similar technologies as described in Section 3 of this Policy	Identifiers Online Activity

(2) Categories of Parties with Whom We Have Disclosed the Personal Information for our Business or Commercial Purposes.

Categories of Parties

Categories of Personal Information

Our affiliates

Vendors providing services to us or on our behalf

Professional services organizations (e.g., legal professionals, accountants, auditors, etc.)

Persons or parties that you instruct or direct us, or provide consent for us, to disclose your personal information to

Third parties as required or permitted to comply with legal and/or regulatory requirements and obligations

The Dalabmart Carrier who designated you as the emergency contact (as applicable)

The Dalabmart Carrier who designated you as receiving a Referral (as applicable)

Parties in connection with legal proceedings

Identifiers

Communication Data

Online Activity

(3) Categories of Personal Information We Have Disclosed for a Business Purpose.

Please see the categories of personal information identified in section 2.B.(a)(1) of this Policy.

C. Referral Program.

For the Referral programs, DalabMart enables DalabMart Carriers to make or initiate Referrals to individuals for participation in Dalabmart Carrier Services. For a Referral, a Dalabmart Carrier voluntarily chooses to participate, selects the individual(s) to invite to participate in a Referral, chooses the method of communication with the referred individual (e.g., SMS/text message, email, etc.), and has full control over the content (e.g., DalabMart provides suggested content, but the Dalabmart Carrier may edit the content). You, as the referring Dalabmart Carrier, have the responsibility for ensuring that the referred individual has consented or otherwise approved of the processing of the personal information for sending Referral communications and for both you and DalabMart to process the referred individual’s personal information. You, as the referring Dalabmart Carrier, (i) must not send communications to people who have not consented or approved of receiving the communications or who have asked you to stop sending the communications; (ii) are responsible for ensuring that the content of a communication is not deceptive, misleading, or false; and (iii) must not send Referral communications to anyone under the age of 18.

D. Aggregated and/or De-Identified Data.

We may aggregate and/or de-identify information collected through the Dalabmart Carrier Services. We may use the aggregated or de-identified data for any purpose, including, without limitation, for research and marketing purposes and may also share such data with any third parties, including, without limitation, advertisers, business partners, sponsors, promotional partners, event promoters and/or any other party.

3. Use of Cookies and Similar Technologies.

We use cookies, web beacons, pixels, session replay, and similar technologies to collect information and personalize your experience with the Dalabmart Carrier Services.

A. Cookies

Cookies are small web files that a site or its provider transfers to your device’s hard drive through your web browser that enables the site’s or provider’s system to recognize your browser and remember certain information.

We use first-party and third-party cookies for the following purposes: (1) to make the Dalabmart Carrier Services function properly; (2) to improve the Dalabmart Carrier Services; (3) to recognize you when you return to our platforms and to remember information you have already provided, such as your preferences; (4) to collect information about your actions and activities over time and across third party websites or other online services in order to deliver content and advertising tailored to your interests; and (5) to provide a secure browsing experience during your use of the Dalabmart Carrier Services.

You may disable the use of cookies by modifying your browser settings. If you choose to disable cookies you may not be able to fully experience the interactive features of the Dalabmart Carrier Services.

B. Web Beacons

Web beacons, also known as web bugs, pixel tags or clear GIFs, are tiny graphics with a unique identifier that may be included on our platforms to deliver or communicate with cookies, in order to track and measure the performance of our platforms and services, monitor how many web visitors we have, and to monitor the effectiveness of our advertising. Unlike cookies, which are stored on the user’s hard drive, web beacons are typically embedded invisibly on webpages (or in an email).

C. Session Replay

We may collect information on your use of our platforms or the Dalabmart Carrier Services, such as pages visited, links clicked, non-sensitive text entered, and mouse and scrolling movements. The information collected may include a recreation of your session interactions on our platforms. We take measures to utilize replay session technology to exclude and block sensitive user information.

D. Online Analytics and Advertising Technologies

We and our third-party vendors may use automated technologies (including cookie identifiers on our platforms), along with other collected information, to tailor ads or deliver content when you are on the Dalabmart Carrier Services or on other devices, apps or websites.

E. Targeted Advertising

We (or our service providers) may use the information we collect, for instance, IP addresses and unique mobile device identifiers, to locate or try to locate the same unique individual across multiple browsers or devices (such as smartphones, tablets, or computers), or work with providers that do this, in order to better tailor content and features and provide you with a seamless experience across devices. If you wish to opt out of such cross device tracking for purposes of interest-based advertising, you may do so through your device settings. We may also use cross-device tracking to help identify individuals accessing our platforms and our users and to serve advertising. This type of advertising is often called “interest-based” or “personalized” advertising and when it occurs on mobile apps, “cross-app” advertising.

You can learn more about interest-based advertising and how to opt-out of receiving tailored advertising managed through third party processes by visiting (i) the Network Advertising Initiative’s Consumer Opt-Out link or (ii) the Digital Advertising Alliance’s Consumer Opt-Out link. These links are provided for convenience purposes only; DalabMart is not responsible or liable for the compliance practices and programs of the companies managing the opt-out processes available through the above links. For information on how to opt-out of targeted advertising through DalabMart’s processes, please see Section 8 (Your Rights and Choices) of this Policy.

Please note that even if you opt-out, you may still receive advertisements from us. However, in that case, the advertising will not be tailored to your interests. Also, we do not control any of the above opt-out links or whether any particular company chooses to participate in these opt-out programs.

F. Mobile Applications

Depending on your permissions, we may receive your personal information from your Internet service and mobile device providers. Users of mobile devices who do not want to receive interest-based advertising may opt-out in several ways. Each operating system, (iOS for Apple phones, Android for Android devices, etc.) provides its own instructions on how to prevent the delivery of in-application targeted advertisements. You should view your device or system “Settings” to determine how you can opt out of use of your device ID for “cross-app” personalized advertising.

G. Marketing Activities.

In addition to the other marketing and advertising activities described above, please see the following additional description of certain marketing and advertising activities.

Look-alike Modeling. We may use personal information and/or link personal information to a third-party cookie or other similar technology to develop audience insights and/or look-alike models in connection with our marketing campaigns, which models are used to market or advertise the Dalabmart Carrier Services on third party platforms (e.g., websites, apps, etc.) to people who exhibit similar characteristics with the look-a-like modeled data.

Audience Insights/Ad Measurement. We may use the personal information collected from or about you and your use of our Dalabmart Carrier Services and platforms to gather audience insights and engage in ad effectiveness measurement. In connection with this activity, we may share personal and transactional information about you and your use of our Dalabmart Carrier Services and platforms with our service providers, processors and business partners for the purposes of ad insight and ad effectiveness measurement reporting (either on an individual user level or an aggregate level), which will be used to create, enhance, and improve our Dalabmart Carrier Services and platforms and to create, enhance, improve, and implement marketing campaigns and content.

Cross-Context Behavioral Advertising. We may engage in targeted marketing or advertising to a Dalabmart Carrier based upon the Dalabmart Carrier’s personal information obtained from the Dalabmart Carrier’s activity across another company’s distinctly-branded websites, applications, or services, however, such activities are only on our behalf and for the benefit of us and the Dalabmart Carrier Services.

We also use your information to personalize your experience. For example, we may personalize the content and features you see when visiting our Dalabmart Carrier Services. In addition, we may personalize advertisements, marketing communications, and recommendations to make them more tailored to your interests.

We may use your personal information for suppression purposes in connection with our marketing and advertising activities.

4. Security.

DalabMart has implemented administrative, organizational, technical, and physical security controls that are designed to safeguard personal information. However, no online activity is ever fully secure or error-free. While we strive to protect your information, we cannot guarantee that your Personal Information is absolutely secure. Please keep this in mind when disclosing any information to DalabMart.

Please recognize that protecting your Personal Information is also your responsibility. We urge you to take every precaution to protect your information when you are on the Internet, or when you communicate with us and with others through the Internet. Change your passwords often, use a combination of letters and numbers, and make sure you use a secure browser. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of your account might have been compromised), or if you suspect someone else is using your account, please let us know immediately by contacting us as indicated in Section 13 (Contact Us) of this Policy.

5. Data Retention.

Our retention of your personal information may vary based upon the nature of our relationship with you (e.g., Dalabmart Carrier, Non-Dalabmart Carrier, etc.) and based upon several factors, including without limitation, the following:

(a) The length of time necessary to fulfill the purpose(s) for which we collected the personal information;

(b) When your relationship with us ceases or terminates;

(c) The length of time it is reasonable to keep records to demonstrate that we have fulfilled our business and legal duties and obligations and contractual commitments (as applicable);

(d) Any limitation periods within which claims can be made;

(e) Any retention periods prescribed by law or recommended by regulators, professional bodies, or associations; and

(f) The existence of any relevant legal proceedings.

6. Third-Party Sites.

Some of the functionality may be provided by third parties and the Dalabmart Carrier Services may link to other third-party websites that are not controlled by DalabMart. These third parties are not under our control and we are not responsible for their privacy policies or practices. If you provide any personal information to any third party or through any such third-party website, we recommend that you familiarize yourself with the privacy policies and practices of that third party.

As part of onboarding or verifying your account, we may ask you to upload a selfie and a photo of your ID. Those images go directly to Persona Identities, Inc. (“Persona”), one of our service providers.

Persona processes these images, including by generating data about your facial geometry (which may be considered to be biometric data in some jurisdictions) for the purposes of verifying your identity and preventing fraud. This may involve comparing the biometric data generated from your selfie to the biometric data generated from your ID, as well as comparing the biometric data generated from your images to the biometric data generated from other images. Persona stores the biometric data and uses it to perform ongoing identity-verification and fraud-prevention screenings and permanently deletes the data when it is no longer needed to fulfill those purposes, or within three years of the initial creation of the data, whichever is sooner. Persona relies on service providers to process the biometric data and other information for these purposes. For more information on Persona’s policies.

Persona sends DalabMart the results of this screening but not the biometric data used to perform it. DalabMart does not collect or have access to the biometric data generated by Persona to perform these services.

7. Children’s Information.

The Dalabmart Carrier Services are not intended for individuals under 18 years of age and we do not knowingly collect personal information from individuals under the age of 18. For clarification, for compliance with the California Consumer Privacy Act of 2018 (as amended), we also do not have knowledge that we sell or share the personal information of individuals under 16 years of age. If a parent or guardian of an individual under the age of 18 believes that we have collected personal information from or about such an individual, please contact us at [email protected]

8. Your Rights and Choices.

A. Your Rights.

You may have rights under certain data protection and privacy laws pertaining to our processing of your personal information. These rights are not absolute, meaning that, as permitted under applicable data protection and privacy laws, we may not be obligated to comply with your request and we can limit the frequency of your requests. For all requests, we will need to verify the identity of the data subject and, if applicable, the identity and authority of the person submitting the request on behalf of the data subject. If we are unable to confirm or validate the identity of the data subject and, if applicable, the identity and authority of the requestor if different than the data subject, then we may reject or deny the request. Subject to applicable data protection and privacy laws, you can exercise your rights free of charge.

Subject to applicable data protection and privacy laws, the following rights may be available:

Type of Right	Description	Exercising Right
Right of Access/Right to Know/Right to Data Portability	This right provides an individual with the opportunity to know what personal information has been collected about them, including the specific pieces of personal information and the right to receive a copy of the personal information in a portable and, to the extent technically feasible, a readily usable format.	Dalabmart Carrier: When logged-in to your Dalabmart Carrier app, you can access the request account data functionality through the following path: account > account data > manage account. Non-Dalabmart Carrier: Contact us at [email protected] and provide (i) your first and last name, email address and address of residency; (ii) identify the right(s) being exercised; (iii) identify your connection to or with DalabMart(e.g., Non-Dalabmart Carrier, etc.) and (iv) in the subject line include “Non-Dalabmart Carrier DSR Request”
Right of Deletion	This right provides an individual with the opportunity to request deletion of personal information. Notwithstanding the fact that a data subject may exercise a right to delete personal information, please note that we will keep a record of all rights requests and we may retain personal information even after receiving and processing a right of deletion request if such retention is permitted or required under applicable data protection and privacy laws.	Dalabmart Carrier: When logged-in to your Dalabmart Carrier app, you can access the delete your account functionality through the following path: account > account data > manage account. Non-Dalabmart Carrier: Contact us at [email protected] and provide (i) your first and last name, email address and address of residency; (ii) identify the right(s) being exercised; (iii) identify your connection to or with DalabMart (e.g., Non-Dalabmart Carrier, etc.) and (iv) in the subject line include “Non-Dalabmart Carrier DSR Request”
Right to Opt-Out of Sale or Sharing of Personal Information Right to Opt-out of Targeted Advertising Right to Opt-In	This right provides an individual with the opportunity to opt-out of having their information sold, shared, or used for purposes of cross-context behavioral advertising, or targeted advertising. State laws have specific definitions of selling, sharing, and targeted advertising. For example, the California Privacy Rights Act of 2020 (“CPRA”) broadly defines “sale” as any sharing of personal information with third parties in exchange for monetary or other valuable consideration. The CPRA defines “sharing” as sharing personal information with a third party for cross context behavioral advertising. This includes sharing personal information in a way that allows third parties to receive certain information such as cookie identifiers, IP addresses and/or browsing behavior to add to a profile about your device, browser or you. Such profiles may enable delivery of interest-based advertising or cross-context behavioral advertising by such third parties within their platform or on other sites. You also have the right to opt-in if you change your mind. This right provides individuals who have chosen to exercise their right to opt-out the opportunity to opt-in for the sale and sharing of their personal information.	Dalabmart Carrier: We may disclose personal information (e.g., identifiers and service and platform usage information) to advertising partners to provide you with personalized ads on third-party platforms, which may constitute a “sale” or “share: of your personal information. To opt-out of the sale or share of personal information, you can log-in to your Dalabmart Carrier app and access the Dalabmart Carrier account level opt-out through the following path account > account data > learn more under marketing choices. You can also opt-out through the browser-level opt-out available here. Opting-out through the browser-level opt-out will not apply to your registered account. If you change your mind, you can opt-in using the same path. Non-Dalabmart Carrier: For non-DalabMart Carriers who have visited our Dalabmart Carrier-related website(s), you may opt-out through the browser-level opt-out option available. If you change your mind, you can opt-in using the same path.
Right to Correct or Rectify Personal Information	Taking into account the nature of the personal information and the purposes of the processing, this right provides an individual with the ability to correct or update inaccurate personal information that we hold about the individual.	Dalabmart Carrier: Please login to your account and correct or update your information. Non-Dalabmart Carrier: Contact us at [email protected] and provide (i) your first and last name, email address and address of residency; (ii) identify the right(s) being exercised; (iii) identify your status (e.g., Non-Dalabmart Carrier, etc.) and (iv) in the subject line include “Non-Dalabmart Carrier DSR Request”
Right to Appeal	This right provides an individual with the opportunity to appeal a decision made by us in connection with a rights request.	All categories of individuals covered by this Policy: contact us at [email protected] and provide (i) your first and last name, email address, and address of residency; (ii) the date that you initially submitted the request; (iii) an overview of the decision you are appealing; (iv) your status (e.g., Dalabmart Carrier, Non-Dalabmart Carrier, etc.); and (v) include the following in the subject line “DSR – Appeal”.
Right of Non-Discrimination and Non Retaliation	This right provides an individual with the right to not be discriminated against as a result of exercising a right provided under applicable data protection and privacy laws. Generally, this right prohibits a Controller from (a) denying an individual access to or use of goods and services, (b) charging different prices or rates for goods and services, or (c) providing a different level or quality of goods or services, as a result of the individual exercising a right under data protection and privacy laws.	All categories of individuals covered by this Policy: DalabMart does not discriminate or retaliate against individuals for exercising applicable privacy rights. If you feel that you have been subject to discrimination as a result of exercising a right provided under data protection and privacy laws, please contact us at [email protected] and provide (i) your first and last name, email address and address of residency; (ii) an explanation of the right(s) exercised and the alleged discriminatory treatment; (iii) your status (e.g., Dalabmart Carrier, Non-Dalabmart Carrier, etc.); and (iv) in the subject line include “Discriminatory Treatment – DSR”.
Right to Limit the Use and Disclosure of Sensitive Personal Information	Under the CPRA, this right provides an individual with the opportunity to direct a business that collects sensitive personal information about the individual to limit its use of the individual’s sensitive personal information to only the use necessary to perform the services or provide the goods reasonably expected by the average individual who requests those services or goods or as otherwise permitted under applicable data protection and privacy laws. This right is limited to sensitive personal information used for the purpose of inferring characteristics about an individual.	All categories of individuals covered by this Policy: DalabMart does not use sensitive personal information for the purpose of inferring characteristics about an individual, therefore we do not offer a path to exercise this right. However, all other rights applicable to personal information are available for sensitive personal information as well. You may exercise any of the other rights available to you, such as the Right of Deletion or the Right to Opt-Out.
Right to Withdraw Consent	This right provides individuals with the opportunity to withdraw their consent where DalabMart has collected their personal information on the basis of such consent.	All categories of individuals covered by this Policy: To withdraw consent where you have previously given your consent to DalabMart, please contact us at [email protected] and provide (i) your first and last name, business email address, and address of residency; (ii) an explanation of where you provided your consent to DalabMart; (iii) your status (e.g., Dalabmart Carrier, Non-Dalabmart Carrier, etc.); and (iv) in the subject line include “Withdraw Consent – DSR”.
Right to Opt-out of Profiling	This right provides individuals with the opportunity to opt out of profiling. The term profiling has specific definitions under state laws and typically means automated processing to analyze an individual’s economic situation, health, personal preferences, interests, reliability, behavior, location or movements in a way that would produce a legal or similarly significant effect.	All categories of individuals covered by this Policy: DalabMart does not engage in this type of profiling of individuals.

Authorized Carrier Requests. For authorized Carriers submitting a request on behalf of a data subject, please contact us at [email protected] and provide (i) the first and last names and email address for the data subject, (ii) the first and last names and business contact information for the Carrier, (iii) evidence of authority (e.g., power of attorney, etc.), (iv) the status of the data subject (e.g.,Dalabmart Carrier, Non-Dalabmart Carrier, etc.), (v) the right(s) being exercised, and (vi) in the subject line include “Authorized Carrier Request”.

Contact DalabMart by Phone: If you do not have access to email or based on your preference, you may exercise any of the rights available to you by calling us at (855) 973-1040.

Contact DalabMart by E-Mail: You may contact us via e-mail ([email protected]) to exercise the following rights: (i) right to correct/rectify personal information, (ii) the right of access/right to know, and (iii) the right to deletion. In your email, please provide (a) your first and last name, email address and address of residency; (b) identify the right(s) being exercised; and (c) in the subject line include “DSR Request”.

B. Your Additional Choices.

i. Commercial Email Messages & Text Messages. You can unsubscribe from our marketing or promotional emails and text messages by using the unsubscribe mechanism in the communication. We will still send you transactional, information, and relationship communications about the use of our Dalabmart Carrier Services, platforms and/or the relationship between us and you. This opt-out option does not apply to DalabMart credit card offerings because these are provided through associated financial institutions. However, you can choose to stop receiving certain prescreened offers of credit that originate from participating nationwide credit reporting agencies, including our prescreened offers, by calling the official Consumer Credit Reporting Industry organization.

ii. Promotional Push Notifications. In the notifications section of the account page on our mobile platforms/apps, you can adjust your promotional push notifications settings by toggling to disable or enable promotional push notifications.

iii. Location Access. You cannot turn off location access in the DalabMart application. You can disable location tracking through your device settings; however, this will prevent you from participating in the Dalabmart Carrier Services.

iv. Cookie Tracking. Please see Section 3 (Cookies and Similar Technologies) of this Policy.

v. Ad Personalization. To adjust your preferences on our ad personalization activities on third party platforms (e.g., websites and apps), please see the right to opt-out of sale or share information in Section 8.A. above.

9. GLBA.

DalabMart is not a bank or financial institution. However, DalabMart may collect, process, retain, and/or disclose non-public personal information (“NPI”) in connection with the DalabMart Crimson program (“Crimson”), which enables you to sign up for certain banking services through our program partner, Starion Bank (“Sponsor Bank”). DalabMart processes such NPI as a service provider to Sponsor Bank, resulting in several important distinctions that we explain below.

When processing NPI as a service provider to Sponsor Bank, your NPI is protected by the federal Gramm-Leach Bliley Act (“GLBA”) and is exempt from U.S. state privacy laws (such as the CPRA).
Our processing of your NPI is governed by Sponsor Bank’s instructions and Privacy Policy, not this Policy. For details on Sponsor Bank’s privacy practices, including your rights, please refer to their Privacy Policy. While DalabMart is not responsible for Sponsor Bank’s Privacy Policy, we strongly encourage you to read it. If you have questions regarding their Privacy Policy or how they handle your NPI, please contact the Sponsor Bank directly.
DalabMart processes NPI collected in connection with Crimson solely to provide the Crimson service, with one exception: we may ask for your opt-in consent to additional uses and/or disclosures of your NPI. If you provide such consent, DalabMart may combine your NPI with other information we collect about you, such as your Dalabmart Carrier activity, and use your combined data to personalize and improve your experience, qualify you for premium offers, and market to DalabMart Carriers like you. If you choose to give consent, you may later revoke your consent. Upon revocation, we will stop processing your NPI for the purposes described in the consent.

10. California Specific Disclosure Requirements.

i. Notice of Financial Incentives.

Under the CPRA, we are required to provide certain disclosures regarding “financial incentives” offered in exchange for your disclosure of personal information to us. We provide several opportunities or programs where individuals can provide personal information to us in exchange for financial incentives, including in connection with participation in survey research, sweepstakes programs, Referral programs, and product and partnership opportunities. In addition, for Referral programs, the referred party or person can also receive incentives for participation. These programs are entirely voluntary and allow us to grow, enhance, and improve our DalabMart Carrierservices and business activities and provide benefits to those who participate. For the various financial incentives that we offer, we have not assigned a monetary value to the data we collect through or in connection with our financial incentive programs; however, based upon our good faith reasonable estimate, the value we receive from your personal information is reasonably equal to the value of the financial incentive we provide to individuals who participate in these programs. The material terms for the financial incentives are available with the applicable offer that you may receive prior to you voluntarily deciding to participate. If you want to opt-out of participating in an incentive program, please either stop participating or email us at [email protected] and include your first and last names, email address, identify the incentive program(s) that you want to opt-out from, and in the subject line, please include“Incentive Program Opt-Out”.

ii. California Shine the Light Law.

The “Shine the Light” requirements under California Civil Code §1798.83 do not apply to the individuals covered under this Policy because we do not engage in the activities covered by this law.

iii. California Reporting Metrics.

11. Nevada.

Under Nevada Revised Statutes Chapter 603A (Security and Privacy of Personal Information) (“Nevada Privacy Law”), companies that qualify as an Operator under Nevada Privacy Law must satisfy certain requirements pertaining to Covered Information (as defined under Nevada Privacy Law). Under Nevada Privacy Law, certain Nevada consumers may opt-out of the sale (as defined under Nevada Privacy Law) of Covered Information. The individuals covered under this Policy are not covered under the Nevada Privacy Law.

12. Cross-Border Transfers of Personal Information.

The Personal Information processed in connection with this Policy, including, without limitation, by us and/or our third-party service providers, may be stored and processed on systems and servers and accessed by persons and parties, located outside of the jurisdiction where you live (including, without limitation, outside of Australia, Canada (including outside of the province in which you live), New Zealand and the United States), including storing, accessing, and processing the Personal Information in the United States and other global locations whose data protection laws may differ from those where you live.

13. Contact Us.

If you have any questions or concerns relating to this Policy or our privacy practices, please contact us at: [email protected] or:

DalabMart, LLC.

Attn: Legal

2526 Hennepin Avenue South

Minnepolis, MN 55405 US

Telephone Number: +1 (646) 944-9972

14. Updates to this Policy.

This Policy may be subject to updates from time to time with or without notice. We recommend that you periodically review this Policy. In the event of any changes to this Policy, we will determine whether or not notice is required and, if notice is required, we will provide appropriate notice taking into account the nature of the changes. Your continued use of our Dalabmart Carrier Services after any updates to this Policy constitutes your agreement and acceptance of this Policy as updated. In the event that you disagree with the changes, your only remedy is to cease using the Dalabmart Carrier Services.