Proverbs Technology, Inc.

Last Updated: April 28, 2026

Table of Contents

1. 1. Introduction and scope
2. 2. Information we collect
3. 3. How we use information
4. 4. How we share information
5. 5. Data retention
6. 6. Data security
7. 7. Your privacy rights and choices
8. 8. Children’s privacy
9. 9. Third-party links and services
10. 10. International data transfers
11. 11. California resident privacy rights
12. 12. Tennessee resident privacy rights
13. 13. Changes to this privacy policy
14. 14. Contact us
15. 
    

1. Introduction and scope

1.1 Overview

Proverbs Technology, Inc. (“Company,” “we,” “us,” or “our”) is a Tennessee technology corporation that provides driver placement and portal assistance services to trucking companies and motor carriers. Our services facilitate the placement and verification of commercial truck drivers within United States Department of Transportation (DOT) systems, including Federal Motor Carrier Safety Administration (FMCSA) and related federal and state regulatory portals.

This privacy policy (“Policy”) explains how we collect, use, disclose, retain, and protect personal information in connection with our services. We are committed to transparency regarding our data practices and to complying with applicable federal, state, and local privacy laws, including, as applicable, the California Consumer Privacy Act of 2018 (CCPA), as amended by the California Privacy Rights Act of 2020 (CPRA), the Fair Credit Reporting Act (FCRA), the Tennessee Consumer Protection Act, the Tennessee data breach notification statute, and Section 5 of the Federal Trade Commission Act.

1.2 Scope and application

This Policy applies to personal information:

1. Collected from commercial drivers and applicants (“Drivers”) who use our services or whose information we process in connection with our services

2. Collected from or on behalf of trucking companies, motor carriers, logistics companies, and fleet operators and their representatives (“Customers”)

3. Collected from visitors to our websites, mobile applications, and online portals (collectively, the “Sites”)

4. Processed in connection with our provision of driver verification, credentialing, placement assistance, and DOT and related portal integration and support services (collectively, the “Services”)

This Policy does not apply to:

1. Third-party websites, applications, or services that we do not own or control, even if accessed through our Sites or Services

2. Personal information processed solely by our Customers for their own independent purposes once they receive it from us, in which case the Customer’s own privacy policies and notices govern

3. Information that is de-identified or aggregated so that it cannot reasonably be linked to an identified or identifiable individual

1.3 Our commitment to privacy

We recognize that privacy is a fundamental right and that personal information related to commercial driving, safety, and employment is particularly sensitive. We are committed to:

1. Providing clear descriptions of our data collection, use, and sharing practices

2. Data minimization. Collecting only the personal information reasonably necessary to provide and improve the Services and meet legal and regulatory requirements

3. Purpose limitation. Using personal information only for disclosed, compatible, or legally required purposes

4. Implementing reasonable and appropriate administrative, technical, and physical safeguards designed to protect personal information

5. Maintaining internal governance processes, training, and oversight to help ensure compliance with this Policy and applicable laws

2. Information we collect

The types and categories of personal information we collect depend on your relationship with us and how you interact with the Services.

2.1 Information collected directly from drivers

When a Driver creates an account, submits information for placement, communicates with us, or otherwise uses the Services, we may collect the following categories of information:

1. Contact and identification information.

1. Full legal name

2. Residential and mailing addresses

3. Telephone numbers

4. Email address

5. Date of birth

6. Social Security number (SSN) where required or permitted by law or for DOT or employment eligibility verification

7. Government-issued identification numbers (for example, driver’s license number, state identification number, passport number)

2. Commercial driver license (CDL) and licensing information.

1. CDL number and state of issuance

2. CDL class and endorsements

3. CDL status, validity dates, and any restrictions

4. Medical certification status and expiration dates

5. Licensing history, including prior states of licensure

6. Records of CDL-related violations, suspensions, or disqualifications, where permitted by law

3. Employment and work history information.

1. Current and prior employers, job titles, and positions

2. Dates of employment

3. Employment status (for example, full-time, part-time, contractor)

4. Reasons for leaving prior positions, where disclosed

5. Employment references and their contact information

6. Professional licenses, training, and certifications

7. Compensation information where voluntarily provided or necessary for certain placements and permitted by law

4. Background, safety, and compliance information.

1. Motor vehicle records, including incidents, violations, and accident history, as allowed by law

2. Criminal history information, where permitted and subject to applicable law and FCRA requirements

3. DOT safety and compliance records linked to your CDL or DOT number

4. Drug and alcohol testing history, including results and refusals, as required or permitted by DOT or other applicable laws

5. Medical qualification and fitness-to-drive documentation and determinations, to the extent required by transportation safety regulations and with appropriate safeguards

6. Training, orientation, and safety course completion records

5. Account, service, and communications information.

1. Account usernames, hashed passwords, and related authentication data

2. Security questions and answers or other authentication factors, where used

3. Driver profile information you provide through our Sites or Services

4. Documents you upload or provide (for example, licenses, medical cards, certifications, resumes)

5. Communications with us, including emails, messages through our Sites, and call records (where permitted by law)

6. Preferences related to job opportunities (for example, routes, schedules, equipment, geographic preferences)

6. Technology, device, and usage information.

1. Internet Protocol (IP) address and approximate location associated with that IP address

2. Device identifiers (for example, device ID, MAC address)

3. Browser type, version, and settings

4. Operating system type and version

5. Pages, screens, and features you access on our Sites, and the dates and times of access

6. Clickstream data, interaction data, and usage patterns on the Sites

7. Device location information when you enable location services or grant us permission through your device or browser settings

2.2 Information collected from customers and customer representatives

In connection with our relationships with Customers, we may collect:

1. Company name, physical and mailing addresses, and primary contact information

2. Business identifiers, including DOT number, motor carrier (MC) number, and relevant regulatory registration numbers

3. Names, job titles, roles, and contact details (such as telephone numbers and email addresses) of Customer employees or representatives who interact with us

4. Account and login credentials for Customer administrative and user accounts

5. Information about Driver candidates Customers seek to verify, qualify, or place, which may include the same categories of Driver information described above

6. Billing, invoicing, and payment information, including limited payment card information processed through third-party payment processors

7. Contractual documents and records, including statements of work, service agreements, and amendments

8. Communications and transaction history with us, including support requests and feedback

2.3 Information collected from third parties

We may obtain information about Drivers and Customers from third-party sources, including:

1. Government and regulatory sources.

1. DOT and FMCSA databases and portals

2. State driver licensing and motor vehicle departments

3. National Driver Register (NDR) or similar registries, as applicable

4. Drug and alcohol clearinghouse and similar federally mandated systems

5. Law enforcement and court records, where lawfully available

2. Consumer reporting agencies and background screening providers.

1. Consumer reports, investigative consumer reports, and related background checks

2. Motor vehicle records and driving history reports

3. Identity verification and address history information

4. Where applicable, credit-related information consistent with FCRA and applicable state laws (for example, if Customers request credit reports as part of certain roles and where legally permitted)

3. Prior employers, references, and training providers.

1. Employment verification information (for example, positions held, dates of employment)

2. Information regarding job performance and reasons for separation, as permitted by law

3. Safety and incident records, including accidents and violations

4. Training and certification completion records from schools, training centers, or online course providers

4. Other service providers and partners.

1. Medical examiners and clinics that perform DOT physical examinations and provide medical qualification information, subject to applicable law

2. Technology partners that integrate with DOT and other regulatory portals

3. Marketing partners who assist us in outreach to Customers, where they lawfully provide business contact information

2.4 Information created or derived by us

In the course of providing the Services, we may create or derive additional information, including:

1. Internal notes and assessments related to Driver qualifications and suitability for certain positions

2. Inferences drawn from Driver data, such as potential route preferences, equipment compatibility, or risk levels, using consistent and non-discriminatory criteria

3. Unique internal identifiers used to link records across systems and ensure accurate matching

4. Aggregated analytics and metrics about placement rates, safety outcomes, and other performance indicators

5. Audit logs and records of access to personal information within our systems

2.5 Information you provide voluntarily

You may voluntarily provide additional information to us, for example by:

1. Completing optional profile fields

2. Filling out surveys or feedback forms

3. Participating in interviews, advisory groups, or beta testing of new features

4. Providing additional documents or explanations to clarify aspects of your background or qualifications

We treat such voluntarily provided information as personal information under this Policy.

2.6 Fair Credit Reporting Act (FCRA) related information

When we obtain or use consumer reports or investigative consumer reports (as those terms are defined in the FCRA) about you from a consumer reporting agency:

1. We will first provide you with a clear and conspicuous written disclosure stating that a consumer report or investigative consumer report may be obtained for employment or placement-related purposes

2. We will obtain your written authorization before ordering such a report, except as otherwise permitted by law

3. We will use the consumer report information only in accordance with the FCRA and applicable state laws

4. If an adverse action is taken based in whole or in part on a consumer report (for example, if we or a Customer decline to move forward with a placement or hiring decision in reliance on the report), we or the Customer, as applicable, will provide any legally required pre-adverse and adverse action notices, including:

1. A copy of the consumer report, where required

2. A summary of your rights under the FCRA

3. The name, address, and telephone number of the consumer reporting agency that furnished the report

4. A statement that the consumer reporting agency did not make the adverse decision and cannot provide specific reasons for the decision

5. Notice of your right to obtain a free additional copy of the report from the consumer reporting agency and to dispute the accuracy or completeness of any information in the report

You have the right under the FCRA to dispute inaccurate or incomplete information in a consumer report directly with the consumer reporting agency. You may also contact us using the information in Section 14 if you believe we have misused or misinterpreted such information.

3. How we use information

We use personal information for the purposes described at the time of collection and as set out below, subject to applicable law.

3.1 Primary purposes: service delivery and driver placement

We use Driver and Customer information to:

1. Provide and manage the Services.

1. Create, maintain, and manage Driver and Customer accounts, profiles, and credentials

2. Enable Drivers and Customers to access and use the Sites and Services

3. Facilitate the submission, tracking, and management of driver applications and placements

2. Verify qualifications and compliance.

1. Confirm Driver identity, CDL status, medical qualification, endorsements, and other required credentials

2. Obtain, review, and maintain required background checks, motor vehicle records, and safety records in compliance with DOT, FMCSA, and other applicable regulations

3. Assist Customers in meeting their obligations to maintain driver qualification files and safety records

3. Facilitate placement and employment-related decisions.

1. Match Drivers with suitable opportunities based on qualifications, preferences, and Customer requirements

2. Provide Customers with Driver information necessary to evaluate candidates and make informed hiring or engagement decisions

3. Support Customers in onboarding Drivers into DOT and related regulatory portals

4. Support DOT and regulatory compliance.

1. Assist with data submissions and portal interactions required or permitted by DOT, FMCSA, and state motor vehicle agencies

2. Maintain records and logs required by applicable transportation safety regulations

3.2 Secondary purposes: operations, improvement, and protection

We also use personal information for broader business and operational purposes, including:

1. Operations and administration.

1. Operating, maintaining, and improving the Sites and Services

2. Managing our relationships and contracts with Customers and vendors

3. Processing payments, invoices, and other financial transactions

2. Analytics and service improvement.

1. Analyzing usage patterns and performance metrics to improve functionality, reliability, and user experience

2. Developing new features, tools, and services to better serve Drivers and Customers

3. Conducting internal research and benchmarking related to safety, performance, and success of placements, using aggregated or de-identified data where feasible

3. Security, fraud prevention, and integrity.

1. Protecting the Sites, Services, and our systems from unauthorized access, cyber threats, and abuse

2. Detecting, investigating, and preventing fraud, misuse, or other harmful activities

3. Enforcing our terms of use and other applicable policies and agreements

4. Legal, regulatory, and risk management.

1. Complying with applicable laws, regulations, and legal processes

2. Responding to lawful requests from law enforcement and regulatory authorities

3. Managing and resolving disputes, claims, and litigation

4. Maintaining appropriate business records and evidence in connection with audits and investigations

3.3 Communications and marketing

We may use contact and account information to:

1. Send operational and transactional communications, such as:

1. Account confirmations and security alerts

2. Application status updates and placement notifications

3. Regulatory or policy notices required by law

2. Respond to your inquiries, requests for support, or feedback

3. Send informational and promotional communications about our Services, new features, events, and opportunities that may be relevant to Drivers or Customers, consistent with applicable law and your communication preferences

You may opt out of receiving non-transactional or marketing communications at any time by following the unsubscribe instructions in the communication or by contacting us as described in Section 14. Even if you opt out of marketing messages, we may still send you non-marketing messages relating to your account, security, or the Services.

3.4 Legal bases (where required)

Where required by applicable law (for example, under certain international data protection frameworks), we rely on one or more of the following legal bases for processing personal information:

1. Performance of a contract or to take steps at your request before entering into a contract (for example, to provide our Services to you or to our Customers)

2. Compliance with legal obligations (for example, DOT and FMCSA regulations, record-keeping requirements, and responding to lawful government requests)

3. Our legitimate interests, where not overridden by your rights and freedoms (for example, to improve the Services, ensure network and information security, and prevent fraud)

4. Your consent, where we expressly rely on consent for a particular processing activity, which you may withdraw at any time, subject to legal or contractual restrictions

4. How we share information

We share personal information with third parties only as described in this Policy, as disclosed at the time of collection, or with your consent, and in each case consistent with applicable law.

4.1 Sharing with customers (trucking companies and motor carriers)

1. We share Driver information with Customers to facilitate employment and engagement decisions and to support compliance and portal-related functions. This may include:

1. Contact, identification, and profile information

2. CDL and licensing status, endorsements, and related details

3. Background, safety, and compliance information, to the extent permitted by law and consistent with FCRA and other requirements

4. Employment history and references obtained or verified through our processes

5. Medical qualification status and documentation required to confirm fitness to drive, subject to applicable laws and with appropriate safeguards

6. Our internal assessments or inferences about suitability for particular positions, when requested by Customers and permitted by law

2. Customer responsibilities and limitations.

1. Customers are independently responsible for their own compliance with employment, privacy, anti-discrimination, and other applicable laws in their handling of Driver information they receive from us

2. We require Customers, by contract, to use Driver information only for legitimate employment-related purposes, including recruitment, qualification, onboarding, and ongoing compliance, and not for unrelated marketing or profiling

3. We require Customers to implement reasonable security measures to protect Driver information and to limit internal access to those with a need to know

3. Allocation of responsibility.

1. Once a Customer receives Driver information from us, the Customer becomes a separate controller or “business” of that information for its own purposes, and its privacy notices and practices govern its further use and retention

2. We are not responsible for a Customer’s independent misuse or failure to protect Driver information, except to the extent required by applicable law or where we are found to have materially contributed to or facilitated such misuse

3. Drivers who have concerns about a Customer’s use of their information may contact the Customer directly and may also contact us using the information in Section 14 so that we can, where appropriate, investigate and address potential contractual violations

4.2 Sharing with service providers and vendors

We engage third-party service providers to perform functions on our behalf. These service providers may access personal information as reasonably necessary to perform their functions, subject to contractual obligations to:

1. Use the information only as instructed by us and for our business purposes

2. Implement appropriate security measures to protect the information

3. Not sell or use the information for their own independent marketing or other purposes without our authorization

Categories of service providers may include:

1. Background screening and consumer reporting agencies

2. Cloud hosting, infrastructure, and data storage providers

3. Software and platform providers that support the Sites and Services

4. Payment processors and financial institutions

5. Professional advisors, including lawyers, accountants, and auditors

6. Customer support and communication tools providers

7. Security and fraud prevention services

4.3 Sharing with government, regulatory, and law enforcement authorities

We may disclose personal information to federal, state, or local government, regulatory, or law enforcement authorities when:

1. Required by law, regulation, subpoena, court order, or other legally binding process

2. Necessary to comply with DOT, FMCSA, state motor vehicle agencies, or similar regulatory requirements, including required filings and portal submissions

3. Necessary to respond to an investigation, audit, inspection, or similar process initiated by a governmental authority

4. We believe in good faith that disclosure is reasonably necessary to protect the safety, rights, or property of Drivers, Customers, the public, or our Company

4.4 Sharing in connection with legal claims and enforcement

We may disclose personal information:

1. To establish, exercise, or defend legal claims

2. To enforce our agreements, terms of use, and other policies

3. To investigate, prevent, or take action regarding suspected illegal activities, fraud, threats to safety, or violations of our policies

4.5 Aggregated and de-identified information

We may create aggregated or de-identified information derived from personal information, which cannot reasonably be used to identify an individual. We may use and disclose such aggregated or de-identified information for any lawful purpose, including analytics, research, and product development. We will not attempt to re-identify de-identified data, and we will require any recipients of such data to refrain from attempting re-identification.

4.6 Business transfers

If we undergo a merger, acquisition, reorganization, sale of assets, financing, or similar transaction, personal information may be transferred as part of that transaction, subject to any applicable legal requirements. In such circumstances, we will take reasonable steps to ensure the successor entity honors this Policy or provides a comparable level of privacy protection, and we will provide notice of any material changes as described in Section 13.

4.7 Sharing with your consent

We may share your personal information with third parties for purposes not described in this Policy when you ask us to or when you have given your explicit consent. You may withdraw such consent at any time, but this will not affect prior disclosures made in reliance on your consent.

4.8 Sale and sharing of personal information (California-specific concepts)

1. For purposes of California law, “sale” generally means disclosing or making personal information available to a third party for monetary or other valuable consideration, and “sharing” generally means disclosing personal information to a third party for cross-context behavioral advertising.

2. Our core business model is to provide Services that match Drivers with Customers and facilitate regulatory compliance. In connection with these Services, we disclose Driver information to Customers to enable employment-related decisions. We treat these disclosures as part of our provision of Services rather than as the sale of Driver data as a commodity.

3. We do not disclose personal information to third parties for their own cross-context behavioral advertising purposes, and we do not use personal information for cross-context behavioral advertising on behalf of third parties.

4. At this time, we do not believe that our disclosures of Driver information to Customers constitute a “sale” or “sharing” of personal information for purposes of the CCPA/CPRA, because:

1. We disclose Driver information to Customers strictly for employment-related evaluation and placement purposes

2. Our agreements with Customers restrict their use of Driver information to those stated purposes and require compliance with privacy and employment laws

3. We do not permit Customers to resell Driver information or use it for unrelated marketing or advertising

5. We may use certain cookies or similar technologies on our Sites for analytics and to improve user experience. These are configured so that they are not used for cross-context behavioral advertising.

6. If our practices change in a manner that would be considered a “sale” or “sharing” of personal information under California law, we will update this Policy, implement appropriate notice and opt-out mechanisms, and, where required, provide a “Do Not Sell or Share My Personal Information” option as set out in Section 11.

5. Data retention

We retain personal information for as long as reasonably necessary to fulfill the purposes described in this Policy, including to provide the Services, comply with legal and regulatory obligations, resolve disputes, and enforce our agreements. Retention periods may vary depending on the category of information and applicable legal or regulatory requirements.

5.1 General retention guidelines

Subject to Section 5.2, we apply the following guidelines:

1. Driver application, placement, and qualification information.

1. We generally retain core Driver application and qualification files, including information collected to assist Customers in maintaining driver qualification records, for up to 7 years after the later of (a) the Driver’s last interaction with us or (b) the last placement or active engagement we facilitated, unless a longer period is required by law or reasonably necessary in connection with actual or anticipated legal proceedings.

2. Background check and verification records.

1. We generally retain background check reports, motor vehicle records, and related verification documentation for up to 7 years after the report or record is obtained or after the last placement decision associated with that report, whichever is later, consistent with common practices related to DOT and FCRA compliance.

3. Account and transactional information.

1. We generally retain account registration data, login history, and transactional records (including invoices, payment records, and support interactions) for up to 7 years after account closure or last activity, to comply with accounting, tax, and regulatory requirements and to maintain security and audit trails.

4. Communications and correspondence.

1. We generally retain routine emails, messages, and support tickets for 5 years, unless a longer period is necessary for dispute resolution, investigations, or compliance.

5. Technology and usage information.

1. We typically retain logs, analytics data, and similar technical information in a form linked to an identifiable user for up to 24 months, after which we either delete it or de-identify and aggregate it for longer-term analysis and service improvement.

These periods are subject to review and may be adjusted to reflect changes in legal requirements or business needs, provided they remain consistent with applicable law.

5.2 Legal obligations, contractual requirements, and litigation holds

In some circumstances, we may retain personal information for longer than the time periods stated above, including:

1. When required to comply with applicable laws, regulations, or regulatory guidance (for example, DOT or FMCSA record-keeping requirements)

2. When necessary to establish, exercise, or defend legal claims or potential claims, in which case we may implement a “litigation hold” and preserve relevant records until the matter is resolved

3. When required by contract with our Customers or service providers, so long as those contractual requirements are consistent with applicable law

5.3 Deletion, de-identification, and secure disposal

When we determine that personal information is no longer needed for the purposes for which it was collected and no longer required to be retained by law or contract:

1. We will delete or destroy the information in a manner designed to prevent unauthorized access or use, such as by securely erasing electronic media or shredding physical documents, or

2. We may de-identify the information so that it can no longer reasonably be linked to an identifiable individual, in which case we may use the de-identified information for analytics, research, or other lawful purposes

We maintain internal policies and procedures regarding records retention and disposal and periodically review these policies to align with current legal and regulatory requirements and industry standards.

6. Data security

We maintain a comprehensive information security program with administrative, technical, and physical safeguards designed to protect personal information against accidental, unlawful, or unauthorized access, destruction, loss, alteration, disclosure, or use.

6.1 Technical safeguards

Our technical safeguards may include, as appropriate:

1. Encryption of personal information in transit using current industry-standard transport layer security protocols

2. Encryption of certain categories of personal information at rest

3. Role-based access controls and authentication systems that limit access to personal information based on job responsibilities and need-to-know principles

4. Multi-factor authentication for administrative and other high-privilege accounts

5. Network security controls such as firewalls, intrusion detection or prevention systems, and network segmentation

6. Regular vulnerability assessments, patch management, and monitoring of systems for suspicious activity

7. Logging and monitoring of access to systems containing sensitive personal information

6.2 Administrative and organizational safeguards

Our administrative safeguards may include:

1. Written information security policies and procedures that govern how we handle and protect personal information

2. Designation of personnel responsible for overseeing information security and privacy compliance

3. Background checks on employees in sensitive positions, where permitted by law

4. Training and awareness programs for employees on data protection, privacy, information security, and appropriate handling of Driver and Customer information

5. Confidentiality obligations in employment, contractor, and vendor agreements

6. Access management processes, including user provisioning and de-provisioning and periodic access reviews

6.3 Physical safeguards

Our physical safeguards may include:

1. Physical access controls to facilities that store servers or paper records containing personal information

2. Visitor sign-in and escort procedures for sensitive areas

3. Secure storage of physical documents (for example, locked cabinets or restricted rooms)

4. Procedures for the secure disposal or destruction of physical records containing personal information

6.4 No guarantee

While we strive to protect personal information using reasonable and appropriate measures, no method of transmission over the internet or method of electronic or physical storage is completely secure. We cannot guarantee absolute security. If you believe that your account or interaction with us is no longer secure, please notify us immediately using the contact information in Section 14.

7. Your privacy rights and choices

Depending on where you reside and how you interact with us, you may have certain rights and choices regarding your personal information. We describe general rights in this section and provide jurisdiction-specific information in Sections 11 and 12.

7.1 Access, correction, and deletion

Subject to applicable law, you may have the right to:

1. Request confirmation of whether we maintain personal information about you and to receive a copy of that information in a reasonably accessible format

2. Request that we correct or update inaccurate or incomplete personal information about you

3. Request that we delete personal information about you, subject to legal and contractual exceptions (for example, information we must retain to comply with DOT or FMCSA rules, to complete a transaction you requested, or to establish or defend legal claims)

7.2 Restrictions, objections, and withdrawal of consent

Subject to applicable law, you may also have the right to:

1. Request that we restrict the processing of your personal information in certain circumstances

2. Object to certain processing activities, such as processing for direct marketing purposes

3. Withdraw your consent to processing where we rely on consent as the legal basis, without affecting the lawfulness of processing prior to withdrawal

7.3 Choices regarding communications

You can manage communications from us in the following ways:

1. Marketing emails may include an unsubscribe link that you can use to stop receiving such emails

2. You may contact us as described in Section 14 to update your communication preferences or to request that we stop sending you marketing communications

We may still send you important non-marketing communications relating to your account, security, or the Services.

7.4 Identity verification and authorized agents

When you submit a request relating to your privacy rights:

1. We may need to verify your identity to a reasonable degree of certainty, taking into account the sensitivity of the information and the nature of your request. This may include asking you to provide certain account information, identification, or other data we already hold about you.

2. In jurisdictions that allow it, you may authorize an agent to make requests on your behalf. We may require the agent to provide proof of authorization (for example, a signed written authorization or power of attorney) and may also require you to verify your identity directly with us or confirm that you authorized the agent to act on your behalf.

7.5 Response timelines

We will make commercially reasonable efforts to respond to your verifiable requests within timeframes required by applicable law. For example, for California residents, we generally will respond to a verifiable consumer request within 45 days of receipt and may extend that period by an additional 45 days when reasonably necessary, in which case we will inform you of the extension and the reason for it.

7.6 Limitations and exceptions

Your rights may be subject to important limitations and exceptions. For example, we may deny or partially deny a request when:

1. We cannot reasonably verify your identity or the authority of your agent

2. Granting the request would adversely affect the rights or freedoms of others

3. The information is needed to comply with legal obligations or regulatory requirements (for example, DOT record-keeping rules)

4. The information is necessary to complete a transaction or provide a service you requested, detect or prevent security incidents or fraud, or maintain the integrity of our systems

5. The information is used for certain internal purposes that are reasonably aligned with your relationship with us and compatible with the context in which we collected it

We will explain the reasons for denying or limiting a request to the extent required by law.

7.7 Non-discrimination

We will not discriminate against you for exercising any of your privacy rights. This means that, consistent with applicable law, we will not:

1. Deny you goods or services

2. Charge you different prices or rates, or impose penalties

3. Provide you with a different level or quality of goods or services

4. Suggest that you may receive a different price, rate, or level or quality of goods or services

However, in some cases, if you request deletion or restriction of certain information, it may affect our ability to provide the Services to you (for example, if we cannot retain required DOT qualification information, we may not be able to facilitate certain placements).

7.8 How to exercise your rights

To exercise any of the rights described in this Section 7 or in the jurisdiction-specific sections below:

1. Submit a request using the contact information provided in Section 14, indicating the nature of your request and the jurisdiction in which you reside

2. Provide sufficient information for us to verify your identity and understand the scope of your request

8. Children’s privacy

Our Services are designed for use by adults in a professional and regulatory context and are not directed to children under 16 years of age.

1. We do not knowingly collect personal information from children under 16. If we become aware that we have collected personal information from a child under 16 without appropriate consent, we will take reasonable steps to delete that information and, if appropriate, terminate any associated account.

2. If you believe that a child under 16 has provided personal information to us, please contact us using the information in Section 14 so that we can investigate and address the issue.

9. Third-party links and services

Our Sites and Services may contain links to or integrations with third-party websites, applications, or services that are not owned or controlled by us, including:

1. DOT, FMCSA, state motor vehicle department, or other government portals

2. External training or certification providers

3. Third-party tools or platforms used by Customers for onboarding, payroll, or human resources functions

This Policy does not apply to the privacy practices of those third parties. We are not responsible for the privacy or security practices of any third-party sites or services. We encourage you to review the privacy policies and terms of any third-party sites or services you visit or use.

10. International data transfers

Our Company is headquartered in the United States, and our Sites and Services are primarily intended for use in connection with U.S. transportation activities and regulations.

1. If you access the Sites or Services from outside the United States, you understand that your personal information may be transferred to, stored in, and processed in the United States or other countries where we or our service providers maintain facilities, which may have data protection laws different from those in your country of residence.

2. To the extent required by applicable law, we will implement appropriate safeguards for cross-border transfers of personal information, such as contractual protections or other mechanisms recognized by relevant regulators.

By using the Sites or Services or providing us with personal information, you acknowledge that your information may be transferred to and processed in the United States and other jurisdictions as described in this Policy.

11. California resident privacy rights

This section applies solely to individuals who are residents of California and provides additional information about our practices and your rights under the CCPA/CPRA, to the extent those laws apply to our processing of your personal information.

11.1 Categories of personal information collected

In the past 12 months, we have collected the following categories of personal information (as defined in the CCPA), to the extent applicable to our relationship with you:

1. Identifiers (for example, name, postal address, unique personal identifiers, online identifiers, IP address, email address, driver’s license number, Social Security number)

2. Categories of personal information described in California Civil Code section 1798.80(e) (for example, signature, physical characteristics or description, bank account or payment card information processed through payment providers)

3. Characteristics of protected classifications under California or federal law (for example, age, and in some cases information that could reveal disability or medical condition when necessary for DOT medical qualification, subject to applicable laws)

4. Commercial information (for example, records of Services purchased, obtained, or considered, and other transaction histories)

5. Internet or other electronic network activity information (for example, browsing history, search history, and interactions with our Sites)

6. Geolocation data (for example, approximate location derived from IP address or device location with your consent)

7. Professional or employment-related information (for example, employment history, qualifications, performance and safety records)

8. Education information, to the extent you provide it, or we obtain it in connection with training or certification programs

9. Inferences drawn from other personal information to create a profile about a Driver, for example to reflect preferences or potential suitability for particular types of positions, where used in a manner consistent with law and non-discrimination requirements

11.2 Purposes for collection and use

We collect and use the categories of personal information described above for the business and commercial purposes outlined in Sections 2 and 3 of this Policy, including to provide the Services, manage our operations, comply with laws, and protect our rights and the rights of others.

11.3 Categories of third parties to whom we disclose personal information

In the past 12 months, we have disclosed the categories of personal information described in Section 11.1 to the following categories of third parties for business or operational purposes:

1. Customers (trucking companies, motor carriers, and related entities)

2. Service providers and contractors who process information on our behalf (for example, background screening agencies, hosting providers, payment processors)

3. Government and regulatory agencies (for example, DOT, FMCSA, state motor vehicle departments)

4. Professional advisors (for example, legal counsel, auditors, consultants)

5. Potential acquirers and other relevant parties in the context of a corporate transaction (subject to appropriate confidentiality protections)

11.4 Sale and sharing of personal information

1. We do not “sell” or “share” personal information (as those terms are defined under the CCPA/CPRA) for cross-context behavioral advertising.

2. As described in Section 4.8, we provide Driver information to Customers strictly for employment-related evaluation and placement purposes and require by contract that Customers use such information only for those purposes and in compliance with applicable law. Based on our current understanding of California law and regulatory guidance, we do not consider these disclosures to be “sales” or “sharing” for cross-context behavioral advertising.

3. We also do not knowingly sell or share the personal information of California residents under 16 years of age.

If our practices change such that we engage in activities considered “selling” or “sharing” personal information under California law, we will update this Policy and provide California residents with the right to opt out of such sale or sharing.

11.5 California privacy rights

Subject to certain limitations and exceptions, California residents may have the following rights:

1. Right to know / right of access.

1. You may have the right to request that we disclose the following information for the 12-month period preceding your request (or as otherwise required by law):

1. The categories of personal information we collected about you

2. The categories of sources from which we collected personal information

3. The business or commercial purposes for collecting personal information

4. The categories of third parties to whom we disclosed personal information

5. The specific pieces of personal information we collected about you

2. Right to delete.

1. You may have the right to request that we delete personal information we have collected from you, subject to legal exceptions (for example, where we must retain information to comply with legal obligations, complete a transaction you requested, detect or prevent fraud, or maintain required records).

3. Right to correct.

1. You may have the right to request that we correct inaccurate personal information that we maintain about you.

4. Right to limit use and disclosure of sensitive personal information.

1. To the extent we process “sensitive personal information” (such as SSN or driver’s license number) as defined under California law, we do so only for the limited purposes permitted by the CCPA/CPRA (for example, to fulfill regulatory and safety obligations, process payments, and protect against fraud). We do not use sensitive personal information for purposes that would trigger a right to limit under the CCPA/CPRA.

5. Right to opt out of sale or sharing.

1. As noted above, we do not currently sell or share personal information for cross-context behavioral advertising. If this changes, we will provide California residents with a method to opt out of such sale or sharing.

6. Non-discrimination.

1. We will not discriminate against you for exercising your CCPA/CPRA rights, consistent with Section 7.7.

11.6 How to exercise your California rights

California residents may exercise their rights under this Section 11 by contacting us as set out in Section 14 and specifying that they are making a “California privacy rights request.” We may ask you for information necessary to verify your identity and process your request, consistent with Section 7.4 and applicable law.

California residents may also designate an authorized agent to make certain requests on their behalf, subject to the requirements described in Section 7.4.

12. Tennessee resident privacy rights

This section provides additional information for residents of Tennessee and describes how we comply with Tennessee laws relating to privacy, data security, and consumer protection.

12.1 Tennessee Consumer Protection Act compliance

1. The Tennessee Consumer Protection Act prohibits unfair or deceptive acts or practices in the conduct of trade or commerce, which include false or misleading statements about our data practices.

2. We are committed to ensuring that the statements in this Policy and in any other privacy-related disclosures or representations we make are accurate, clear, and not misleading.

3. If we materially change our data practices, we will update this Policy and, where required, provide additional notice so that you have accurate information about our collection, use, and sharing of personal information.

12.2 Tennessee data breach notification

1. Under Tennessee law, if we become aware of a security breach that results in the unauthorized acquisition of unencrypted personal information of Tennessee residents, we will provide notification to affected individuals without unreasonable delay, consistent with any measures necessary to determine the scope of the breach and restore the integrity of the data system.

2. If a security breach affects the personal information of more than the threshold number of Tennessee residents specified in applicable law, we will also provide notice to the Tennessee Attorney General as required.

3. Notifications may be provided by email, written notice, telephone, or other legally permitted means and will include, to the extent required by law:

1. A general description of the incident

2. The types of personal information reasonably believed to have been acquired

3. Steps we have taken to investigate and mitigate the breach

4. Guidance on steps you can take to protect yourself from potential harm

12.3 Additional rights and protections under Tennessee law

As a Tennessee resident:

1. You are entitled to accurate and non-deceptive information about our privacy and security practices, as described throughout this Policy.

2. You are entitled to receive timely notice of certain security breaches, as described in Section 12.2.

3. You may submit complaints regarding our privacy practices to the Tennessee Attorney General or other appropriate regulatory authorities, in addition to contacting us directly as described in Section 14.

4. You may exercise the general privacy rights and choices described in Section 7, subject to the limitations and exceptions described there and in applicable law.

 

13. Use of SMS and Text Messaging

1. Proverbs Technology, Inc. may use phone numbers you provide to send transactional or service-related text messages (such as screening status updates, appointment reminders, account notifications, or other important communications) through services including Zoom Phone or similar providers. With your prior consent, we may also send promotional or marketing text messages.

2. By providing your mobile phone number, you consent to receiving such text messages from us. Message and data rates may apply. Message frequency may vary.

3. You may opt out of receiving text messages at any time by replying STOP to any text message we send you, or by contacting us using the information in Section 15. We will honor your opt-out request as promptly as required by applicable law. Please note that opting out of marketing messages will not affect transactional or service-related messages necessary for us to provide the Services. You may receive help by replying HELP to any text message we send you, or by contacting us using the information in Section 15.”

 

14. Changes to this privacy policy

4. We may update or modify this Policy from time to time to reflect changes in our practices, technologies, legal requirements, or other factors.

5. When we make material changes to this Policy, we will:

1. Update the “Last Updated” date at the top of this Policy, and

2. Provide additional notice as appropriate under the circumstances (for example, by posting a prominent notice on our Sites, by email, or through in-service notifications).

6. Your continued use of the Sites or Services after the effective date of any updated Policy constitutes your acknowledgment of the updated Policy, to the extent permitted by law.

We encourage you to review this Policy periodically to stay informed about our data practices.

15. Contact us

If you have questions, concerns, or requests regarding this Policy or our privacy practices, or if you wish to exercise your rights as described above, you may contact us using the following methods:

1. By mail.
   Proverbs Technology, Inc.
   Attn: Privacy Office
   PO Box 2351
   Cookeville, TN 38502
2. By telephone.
   432-653-0104
3. By email.
   info@readyfordot.com

When contacting us, please include your name, contact information, relationship to us (for example, Driver or Customer representative), and a clear description of your request or concern. Please note that telephone calls and video conference calls (such as Zoom or similar platforms) may be recorded and monitored for quality assurance, training, compliance, and dispute resolution purposes. If you are a resident of California or another jurisdiction with specific privacy rights, please indicate your jurisdiction so that we can apply the appropriate legal framework to your request.