PEAKCREWS™ PRIVACY POLICY

Version 2 | Effective Date: July 15, 2025 | Next Review: July 15, 2026

PeakCrews, LLC ("PeakCrews," "we," "us," or "our") is committed to protecting your privacy and personal data. This Privacy Policy (“Policy”) explains how we collect, use, disclose, and safeguard Personal Information when you visit or use our website, mobile application, or otherwise interact with our services (collectively, the “Platform”). It also describes your rights and choices regarding your Personal Information.

1. Scope

This Policy applies to Personal Information about the following individuals:

• Subscribers: Businesses (typically subcontractors) that subscribe to the Platform to manage rosters, projects, and workforce readiness.
• Workers: Individuals whose profiles, assignments, or credentials are managed through a Subscriber's account.
• General contractors and site stakeholders: Organizations or users granted visibility into project readiness under a Subscriber's deployment.
• Visitors: Individuals browsing public sections of the Platform.
• Applicants & Leads: Those inquiring about employment, partnerships, or services.

This Policy does not apply to:

• Information about PeakCrews employees or contractors collected under a separate internal policy.
• Personal Information collected by third-party websites or services linked from our Platform.

2. Key Definitions

• Personal Information: Any information that identifies or could reasonably identify you, directly or indirectly, such as name, email, postal address, phone number, or device identifiers.
• Sensitive Personal Information: A subset of Personal Information requiring additional protections under U.S. state laws, including Social Security number, precise geolocation, biometric data, or financial account credentials.
• Controller / Business: The entity determining the purposes and means of processing Personal Information (PeakCrews).
• Processor / Service Provider: An entity processing Personal Information on behalf of the Controller.

3. Information We Collect

We collect Personal Information through various means, including directly from you, automatically via the Platform, and from third parties. A detailed breakdown is available in our Data Collection Table [link to table], which categorizes information types, sources, and purposes.

4. How We Use Your Information

We process Personal Information to:

• Operate the Platform (Contract performance): create and manage Subscriber accounts, authenticate users, coordinate rosters, assignments, compliance checks, and readiness workflows.
• Verify Compliance (Legal obligation; consent): conduct identity, license, and background checks where permitted by law or with your explicit consent.
• Billing & Subscription (Contract performance; legal obligation): process subscription fees, maintain accounts receivable, and issue invoices or tax documents as required.
• Maintain Security & Integrity (Legitimate interests): detect and prevent fraud, abuse, unauthorized access, and vulnerabilities.
• Improve Services (Legitimate interests): analyze usage patterns to enhance features, performance, and user experience.
• Communicate (Contract performance; consent): send transactional messages, support responses, updates, and, with consent where required, marketing communications.
• Legal Compliance (Legal obligation): comply with subpoenas, court orders, or other legal processes, and enforce our agreements and policies.

Legitimate interests include operating, improving, and securing the Platform and protecting our business and users from harm.

5. How We Share Your Information

We do not sell your Personal Information. We share it only as described below:

6. Cookies & Tracking Technologies

We and our partners use cookies, pixels, SDKs, and similar technologies to support essential Platform functionality, analytics, and advertising. You may manage your preferences through our Cookie Preferences banner or browser settings. We honor Global Privacy Control (GPC) signals where required by law. For details, see our Cookie Policy [link].

7. Data Retention

We retain Personal Information only as long as necessary to fulfill the purposes outlined in this Policy, satisfy legal obligations (e.g., tax records for 7 years), resolve disputes, and enforce our agreements. Afterwards, data is deleted or irreversibly anonymized.

8. Security

We employ administrative, technical, and physical safeguards—including encryption, firewalls, access controls, regular security assessments, and vendor due diligence—to protect Personal Information. No system is completely secure; however, we strive to protect your data.

9. International Transfers

Your Personal Information may be transferred to and processed in the United States. When required by law, we use Standard Contractual Clauses or other approved mechanisms to ensure adequate protection for cross-border transfers.

10. Your Privacy Rights

Depending on your state of residence, you may have the right to:

• Access or Know what Personal Information we hold.
• Correct inaccurate or incomplete information.
• Delete Personal Information, subject to legal exceptions.
• Portability: receive a copy in a structured format.
• Opt-Out of certain processing, including targeted advertising.
• Limit Use of Sensitive PI.
• Non-Discrimination: we will not retaliate for exercising these rights.

To exercise your rights, contact us at info@peakcrews.com or visit our Privacy Rights Portal [link]. We will verify your identity and respond within the timeframe required by applicable law (generally 45 days with a possible 45-day extension).

11. Children’s Privacy

Our Platform is not intended for individuals under 16. We do not knowingly collect Personal Information from minors under 16. If we learn that we have collected such information, we will promptly delete it.

12. Changes to This Policy

We may update this Policy to reflect changes in legal or operational requirements. Material changes will be communicated at least fourteen (14) days before they take effect via email or in-app notification. Continued use after the effective date constitutes your acceptance.

13. Contact Us

• PeakCrews, LLC
• Attn: Privacy Officer
• [Street Address]
• Dallas–Fort Worth, Texas [ZIP], USA
• Email: info@peakcrews.com
• Phone: +1 (888) 555‑0123

14. General Provisions

• Governing Law. Texas law governs this Policy, without regard to conflict-of-law rules.
• Severability. If any provision is invalid, the remainder continues in effect.
• Entire Agreement. This Policy, our Terms of Service, and Cookie Policy constitute the complete agreement regarding your Personal Information.