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Privacy Policy

Privacy Policy Shift1Up LLC · Last Updated: March 2026 Last Updated: [3/2026] Shift1Up LLC (“Shift1Up,” “we,” “us,” or “our”) is a consulting-based recruiting platform that connects CDL drivers with motor carriers. This Privacy Policy describes how Shift1Up collects, uses, and shares information about you, as well as your rights and choices regarding such information. This Privacy Policy applies to any website, online form, or digital service operated by Shift1Up that links to this Privacy Policy (collectively, the “Services”). This includes, but is not limited to: https://shift1up.com ! TOP This Privacy Policy is designed to help you understand how we collect, use, process, and share your personal information, and to help you understand and exercise your privacy rights. If you are a resident of California, Colorado, Connecticut, Utah, Indiana, Iowa, or Virginia, please see the “California Notice at Collection & Supplemental Notice for Residents of Certain Other States” section below for information about rights that may apply to you. If you have any questions or wish to exercise these rights, please contact us as set out in the “Contact Us” section. 1. Scope and Updates to This Privacy Policy 2. Personal Information We Collect 3. How We Use Your Personal Information 4. How We Disclose Your Personal Information 5. SMS, Text Messages, and Other Communications 6. Your Privacy Choices and Rights 7. Security of Your Information 8. Retention of Personal Information 9. California Notice at Collection & Supplemental Notice for Residents of Certain Other States 10. Children’s Information 11. Other Provisions 12. Contact Us 1. Scope And Updates To This Privacy Policy This Privacy Policy applies to all personal information processed by Shift1Up. By visiting or accessing the Services, you acknowledge and agree that you have read and understood this Privacy Policy. Changes to our Privacy Policy. We may revise this Privacy Policy from time to time in our sole discretion. If there are any material changes to this Privacy Policy, we will notify you as required by applicable law. You understand and agree that you will be deemed to have accepted the updated Privacy Policy if you continue to use our Services after the new Privacy Policy takes effect. An Important Note: This Privacy Policy does not apply to any of the personal information that we process on behalf of carriers, recruiters, or other third-party clients through their use of our Services (“Customer Data”). Our carrier and recruiter clients’ respective privacy policies govern their collection and use of Customer Data. Our processing of Customer Data is governed by the contracts that we have in place with our clients, not this Privacy Policy. Any questions or requests relating to Customer Data should be directed to those clients. 2. Personal Information We Collect The categories of personal information we collect depend on how you interact with us and the requirements of applicable law. We collect information that you provide to us, information we obtain automatically when you use our Services, and information from other sources such as third-party services and organizations, as described below. For residents of certain states, including California, additional disclosures about the information we collect is available in our supplemental disclosure below. A. Personal Information You Provide to Us Directly We may collect personal information that you provide to us. Account Creation. We may collect personal information when you create an account as a driver or carrier. This may include your first name, last name, phone number, email, home address, commercial driving history, and business contact information. Job Applications. We may post job opportunities on our Services or redirect you to a third-party application process. If you respond to one of these postings, we may collect your job history, consulting contact information, and other personal information relevant to the application. If you are applying for a driver job, we may collect additional personal information including Commercial Driver’s License (“CDL”) data, driving records, and other information relevant to your application. Payments. We may collect personal information and details associated with payments made by carrier clients, including billing contact and account information. Payments may be processed by third-party payment processors, and we may receive information related to your transaction (e.g., billing confirmation or failure). Your Communications. We may collect personal information, such as email address or phone number, when you contact us or interact with other users through the Services. This includes communications between drivers and carriers, as well as support requests sent through our site. Location Information. We may collect approximate or precise location information (e.g., IP-based geolocation or device-based GPS) to help match drivers with nearby jobs or carrier opportunities. Surveys. We may collect personal information when you choose to participate in user surveys or feedback opportunities. Sweepstakes or Contests. We may collect personal information if you enter any promotional campaigns offered through the Site. Events. We may collect personal information from individuals at recruiting events, conferences, or webinars hosted or attended by Shift1Up. Business Development. We may collect personal information from individuals or entities interested in partnering with Shift1Up to expand job offerings or services. B. Personal Information Collected Automatically We may collect personal information automatically when you use our Site. Automatic Collection of Personal Information. We may collect certain information automatically when you use the Site, such as your Internet protocol (“IP”) address, device identifiers, browser type, general location, and interaction data (e.g., which pages you visit, how long you stay, and links clicked). Cookie Policy (and Other Technologies). We, as well as third parties that provide content, advertising, or other functionality on our Site, may use cookies, pixel tags, and other technologies (“Technologies”) to automatically collect information through your use of our Site. Cookies. Cookies are small files placed in your browser to store preferences or track activity. Pixel Tags/Web Beacons. These may be used to track user behavior on the Site or in emails (e.g., if an email was opened or a link clicked). We use these technologies for the following: Analytics. We may use third-party tools like Google Analytics, LinkedIn Analytics, or others to understand how users interact with our Site. Operational Necessity. These include cookies or scripts used to prevent fraud or facilitate site functionality. Preferences and Functionality. These cookies help remember your preferences and streamline use of the Services. Advertising and Targeting. We may use third-party advertising technologies like Facebook Connect to deliver customized ads. See “Your Privacy Choices and Rights” below to understand your choices regarding these Technologies. C. Personal Information Collected from Other Sources Third-Party Services and Sources. We may obtain personal information about you from other sources, including through third-party services and organizations. This may include information from a background screening provider, a prior employer or recruiter, or information from your profile on third-party job board sites where Shift1Up listings appear. We also may receive information from third-party sign-in providers in connection with your access to our Services. 3. How We Use Your Personal Information We use your personal information for a variety of business purposes, including to provide our Services, for administrative purposes, and other purposes as permitted by law and described below. A. Provide Our Services We use your information to provide our Services, such as: Connecting drivers with relevant trucking opportunities; Matching carriers with qualified CDL driver consulting; Sending job alerts, lead notifications, and application tracking updates; Responding to contact requests submitted on our Site; Fulfilling our contractual obligations; Processing your payments for our Services; Answering requests for customer support; Protecting your or another individual’s vital interests; Performing tasks in the public interest; Communicating with you about platform features and consulting activity; and Allowing you to register for conferences and events. B. Administrative Purposes We use your information for various administrative purposes, such as: Pursuing the legitimate interests of our business or a third party, network and information security, and fraud prevention, etc.; Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity; Measuring interest and engagement in our business; Improving, upgrading, or enhancing our business; Developing new services; Ensuring internal quality control and safety; Authenticating and verifying individual identities, including requests to exercise your rights under this Privacy Policy; Debugging to identify and repair errors with our Services; Auditing relating to interactions, transactions, and other compliance activities; Sharing personal information with third parties as needed to provide services; Processing employment or contractor inquiries and participation in Shift1Up’s consulting program; Ensuring the safety and security of employees, contractors, and properties; Enforcing our agreements and policies; Carrying out activities that are required to comply with our legal obligations; and Other internal uses that are reasonably aligned with the expectations of our prospective and existing employees. We may use your information for other legitimate business purposes as permitted by law. C. With Your Consent We may use personal information for other purposes that are clearly disclosed to you at the time you provide personal information or with your consent. D. Other Purposes We also use your personal information for other purposes as requested by you or as permitted by applicable law. De-identified and Aggregated Information. We may use personal information to create de-identified and/or aggregated information, such as demographic information, information about the device from which you access our Services, or other analyses we create. 4. How We Disclose Your Personal Information We disclose your personal information to third parties for a variety of business purposes, including to provide our services, to protect us or others, or in the event of a major business transaction such as a merger, sale, or asset transfer, as described below. A. Disclosures to Provide our Services The categories of third parties with whom we may share your personal information are described below. Service Providers. We may share your personal information with our third-party service providers and vendors that assist us with the provision of our Services. This may include service providers and vendors that provide us with email marketing, data analytics, site hosting, lead tracking, applicant management, and customer service tools. Carrier Clients. We may share your personal information with carriers and other clients that use our platform to receive CDL driver consulting. Our carrier clients include, but are not limited to, motor carriers, owner-operators, and recruiting firms who are seeking drivers and may contact you directly. Affiliates. We may share your personal information with our company affiliates for example: for our administrative purposes, IT management, or for them to provide services to you or support and supplement the Services we provide. Advertising Partners. Through our Services, we may share your personal information with third-party advertising partners. These third-party advertising partners may set Technologies and other tracking tools on our Services to collect information regarding your activities and your device (e.g., your IP address, cookie identifiers, page(s) visited, location, time of day). These advertising partners may use this information (and similar information collected from other services) for purposes of delivering personalized advertisements to you when you visit digital properties within their networks. This practice is commonly referred to as “interestbased advertising,” “cross-context behavioral advertising,” or “personalized advertising.” We may also share your personal information with third parties as appropriate and permitted by law. The privacy choices you may have about your personal information are determined by applicable law and are described in Section 5 below. B. Disclosures to Third Parties We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order, subpoena, or regulatory audit; protect your, our, or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity. C. Disclosure in the Event of Merger, Sale, or Other Asset Transfers If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, your information may be sold or transferred as part of such a transaction, as permitted by law and/or contract. 5. SMS and Text Messages And Communications By signing up for one or more text message programs (“SMS Messaging”), or by submitting your telephone number to us, or by otherwise agreeing to or requesting in any way to receive text messages from or on behalf of Shift1Up, you agree to be bound by our Terms of Use and this Privacy Policy. This includes, but is not limited to, your agreement to the arbitration provisions (if applicable) and your agreement to waive your right to participate in any class action that relates in any way to your receipt of text messages. Each time you use SMS Messaging you will be deemed to have accepted these terms. GENERAL AGREEMENTS By agreeing to and using the SMS Messaging, you (i) represent and warrant that you are at least 18 years of age and (ii) agree that you are the authorized account holder of the carrier which issued your mobile telephone number. In offering the SMS Messaging, we agree to: (i) comply with this section; and (ii) process unsubscribe or opt-out requests received from you in a timely manner. CONSENT If you provide express written consent to receive SMS Messaging services from us, we will send you such messages via an automatic telephone dialing system. Your consent may be provided by: (i) manually entering your phone number, (ii) clicking a checkbox, or (iii) otherwise indicating that you agree to receive such messages. Your consent to receive marketing text messages is not required and is not a condition to purchase any services or to be connected to employment opportunities. If you receive an unwanted text message, you may opt out by following the instructions in the message. We do not disclose your opt-in data and consent preferences to any third parties other than our messaging service providers. DELIVERY OF MESSAGES Delivery of text messages is subject to effective transmission from your wireless service provider/network operator and may vary depending on Your network and cell phone carrier. We are not liable for any delays in the delivery and/or receipt of text messages. ACTIVATION When you opt-in to the SMS Messaging service, we will send you an SMS message with an activation code to verify your telephone number. You will receive one (1) message with the activation code. You can cancel the SMS service at any time, just reply "STOP" to the message. After you send the SMS message "STOP" to us, we will send you an SMS message to confirm that you have been unsubscribed. After this, you will no longer receive SMS messages from us. If you want to join again, just sign up as you did the first time and we will start sending SMS messages to you again. If at any time you need assistance, just reply "HELP" to the message. After you send the SMS message "HELP" to us, we will respond with instructions on how to use our service as well as how to unsubscribe. YOUR USE You must not and must not attempt to or permit another person to: 1. Use SMS Messaging or the information or content disclosed to You via SMS Messaging: a. in any way which is unlawful, offensive or results, or could result, in damage to property or injury to any person, including by harassing or threatening people; b. in a way which infringes our or any other person's rights (including intellectual property rights and moral rights); or c. knowingly transmit any virus, worm, Trojan horse or other disabling feature to or via SMS Messaging. NOT REQUIRED FOR EMPLOYMENT, SERVICES, OR CONSULTING Use of SMS Messaging is not required as a condition of being connected to employment or using our platform. FEES We do not charge you to receive text messages, but standard message and data rates may apply. You are responsible for any charges from your telecommunications provider. SUPPORTED CELL PHONE CARRIERS This SMS service is available on participating wireless carriers. Availability may vary SAFETY OF MESSAGES You understand that text messages we send may be seen by anyone with access to your phone. Accordingly, you should take steps to safeguard your phone and Your text messages if you want your messages to be secure. NO GUARANTEE Shift1Up and its service providers do not guarantee that SMS Messaging will operate error-free on your mobile device. INTELLECTUAL PROPERTY Unless otherwise stated, Shift1Up owns or licenses the content in SMS messages. You may not reproduce, distribute, or use the content for commercial purposes without authorization. TERMINATION We may suspend or terminate your SMS Messaging access at any time without notice and for any reason. DATA RETENTION Data obtained through SMS Messaging or your use of our Services may include your mobile number, message content, date, time, location data, and delivery information. We retain this and other personal information only for as long as necessary to fulfill the purposes outlined in this Privacy Policy, comply with our legal obligations, resolve disputes, enforce our agreements, or as otherwise permitted by applicable law. 6. Your Privacy Choices And Rights Email Communications. If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails. Note that you will continue to receive transaction-related emails regarding Services you have requested. We may also send you certain non-promotional communications regarding Shift1Up and our Services, and you will not be able to opt out of those communications (e.g., communications about updates to this Privacy Policy). Text Messages. If you receive an unwanted text message from us, you may opt out of receiving future text messages from us by following the instructions in the text message you have received from us or by otherwise contacting us as set forth in “Contact Us” below. Mobile Devices. We may send you push notifications through our mobile application. You may opt out from receiving push notifications by changing the settings on your mobile device. With your consent, we may collect precise locationbased information via our mobile tools to help connect you with nearby opportunities. You can opt out by adjusting your location settings. Phone calls. If you receive an unwanted phone call from us, you may opt out of receiving future phone calls from us by following the instructions which may be available on the call or by otherwise contacting us as set forth in “Contact Us" below. “Do Not Track.” Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that Shift1Up does not respond to DNT signals or similar mechanisms transmitted by web browsers. Cookies and Personalized Advertising. You may stop or restrict the placement of cookies and similar tracking technologies on your device or remove them by adjusting your preferences as your browser or device permits. Google provides tools to opt out of certain data collection: https://tools.google.com/dlpage/gaoptout https://www.google.com/settings/ads/onweb/ Our advertising partners are required to provide opt-out tools. You may opt out of certain personalized ads through: https://www.aboutads.info/choices (DAA - websites) https://www.aboutads.info/appchoices (DAA - mobile apps) https://www.networkadvertising.org/choices/ (NAI) Mobile device settings: iOS: “Limit Ad Tracking” Android: “Opt out of Interest-Based Ads” Please note that opt-outs apply only to the specific browser or device used and must be repeated across each browser or device you use. Shift1Up is not responsible for third-party compliance with opt-out settings or mechanisms. 7. Security Of Your Information We take steps to ensure that your information is treated securely and in accordance with this Privacy Policy. This includes using reasonable administrative, technical, and physical safeguards designed to protect your information. However, no system is completely secure, and we cannot guarantee the absolute security of your personal information. By using our Services or submitting information to Shift1Up, you acknowledge and accept the risks of data transmission over the internet and agree that we may communicate with you electronically about privacy, security, and administrative matters. In the event of a security breach involving your information, we may notify you electronically, by posting a notice on our site, by sending an email, or by other means as permitted by law. 8. Retention Of Personal Information We retain the personal information we collect as described in this Privacy Policy for as long as necessary to fulfill the purposes for which it was collected, including to operate the Shift1Up website and services, resolve disputes, enforce our agreements, and comply with applicable legal and regulatory obligations. The length of time we retain personal information depends on several factors, including the nature of the data, the purpose for which it was collected, and our legal or regulatory obligations. In determining how long to retain your information, we consider the volume, nature, and sensitivity of the data; the potential risk of harm from unauthorized use or disclosure; and whether we can achieve our purposes through other means. We endeavor to retain personal information in accordance with applicable data retention laws and industry standards. 9. Notice at Collection & Additional Disclosures for Residents of Certain Other States This section applies to residents of U.S. states with comprehensive privacy legislation, including but not limited to California, Colorado, Connecticut, Utah, Virginia, Indiana, and Iowa (“Applicable State Laws”). If you are a resident of one of these states, you may have additional rights under your state’s privacy law. This section describes those rights and how you can exercise them. We collect, use, and disclose personal information for business purposes as outlined in this Privacy Policy. The following table provides a summary of (i) the categories of personal information we have collected in the past 12 months and (ii) the categories of third parties with whom we have disclosed personal information for a business purpose. Category of Third Parties Category of Personal Information Collected by Personal Information is Shift1Up Disclosed to for a Business Purpose Consulting partners (e.g., motor carriers to whom driver leads are sent) Service providers Business partners Identifiers. Examples may include your name, postal address, (including, but not limited to, trucking carriers with online identifier, Internet Protocol address, email jobs listed via our Services) address, CDL number, and other similar identifiers. Affiliates Advertising networks Internet service providers Data analytics providers Government entities Protected classification characteristics under Consulting partners (e.g., California or federal law. motor carriers to whom Examples may include your age, race, citizenship, driver leads are sent) religion or creed, marital status, medical condition, physical or mental disability, sex, and veteran or Service providers military status. Affiliates Internet or other electronic network activity. Service providers Examples may include cookies and data related to your interactions with our online Services/advertisements. Affiliates Advertising networks Consulting partners (e.g., Geolocation data. Examples may include your GPS location or location motor carriers to whom driver leads are sent) data derived from an IP address. Service providers Affiliates Consulting partners (e.g., Professional or employment-related information. Examples may include current or past job history and evaluations provided by previous employers. motor carriers to whom driver leads are sent) Service providers Affiliates Non-public education information (per the Family Consulting partners (e.g., Educational Rights and Privacy Act). motor carriers to whom Examples may include your education records directly driver leads are sent) related to a student maintained by an educational institution or party acting on its behalf, such as grades, and transcripts. Inferences drawn from other personal information to create a profile about a consumer. Examples may include information about your job interests based on data gathered during your use of Shift1Up’s Service. Service providers Affiliates Consulting partners (e.g., motor carriers to whom driver leads are sent) Advertising networks Affiliates Consulting partners (e.g., Sensitive Data. motor carriers to whom Examples include your social security number, driver’s driver leads are sent) license number, precise geolocation, and healthrelated information. Service providers Affiliates The categories of sources from which we collect personal information and our business purposes are set forth in the section titled “Personal Information We Collect.” The business purposes for which we collect personal information are described in detail in the section titled “How We Use Your Personal Information” and include: To provide our Services to you; For our administrative purposes; To advertise and market our Services to you; With your consent, and, To comply with law. A. Data Retention We retain the personal information we receive as described in this Privacy Policy based on the following criteria. We will retain personal information for as long as you use our website or Services, or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, or based upon such other criteria required to comply with contracts, our policies, and applicable laws. B. Right to Opt-Out of Certain Sales and Sharing Residents of certain states have the right to opt out of the “sale” of their personal information as well as “sharing for purposes of targeted advertising.” A “sale” is defined broadly and includes the transfer of personal information by a business to a third party for valuable consideration (even if there is no exchange of money). Depending on your use of our Services, we may “sell” or “share” your personal information for purposes of delivering targeted advertisements. The chart below details the categories of personal information we have “sold” or “shared for purposes of targeted advertising” and the categories of relevant third-party recipients (over the past 12 months): Personal Information “Sold” or “Shared for Targeted Advertising” Category of Personal Information Category of Third Parties to Whom Information Was “Sold” or “Shared” Identifiers e.g., name, email address, online identifiers, IP address Internet or other electronic network Advertising networks Data analytics providers activity Advertising networks e.g., cookies, usage data, interaction Data analytics providers data Geolocation data e.g., IP-based location or mobile Advertising networks device GPS Inferences drawn from other personal information e.g., interest-based profiles Advertising networks Social media platforms The business purposes for which we “sell” or “share” your personal information are described in detail in the section titled “How We Use Your Personal Information” and include: To advertise and market our Services to you; Providing relevant job opportunities to drivers; and Generating qualified driver matches for carriers. Shift1Up does not have actual knowledge of any “sale” of personal information of minors under 16 years of age. You may limit such sharing by following the instructions found above in the section titled “Your Privacy Choices and Rights,” by clicking on the “Your Privacy Choices” link found [here], or by contacting us as set forth in the “Contact Us” section below. As described in the “Your Privacy Choices and Rights” section above, to the extent that our processing of cookies and similar tracking technologies is considered a “sale” or “sharing for purposes of targeted advertising” under California or other Applicable State Laws, the following additional options are available: Google provides tools to allow you to opt out of the use of certain information collected by Google Analytics at https://tools.google.com/dlpage/gaoptout and by Google Analytics for Display Advertising or the Google Display Network at https://www.google.com/settings/ads/onweb/. The companies we work with to provide you with targeted ads are required by us to give you the choice to opt out of receiving targeted ads. Most of these companies are participants of the Digital Advertising Alliance (“DAA”) and/or the Network Advertising Initiative (“NAI”). To learn more about the targeted ads provided by these companies, and how to opt out of receiving certain targeted ads from them, please visit: (i) for website targeted ads from DAA participants: https://www.aboutads.info/choices (ii) for app targeted ads from DAA participants: https://www.aboutads.info/appchoices (iii) for targeted ads from NAI participants: https://www.networkadvertising.org/choices/ Opting out only means that the selected participants should no longer deliver certain targeted ads to you, but does not mean you will no longer receive any targeted content and/or ads (e.g., in connection with the participants’ other customers or from other technology services). You may also limit our use of information collected from or about your mobile device for purposes of serving targeted ads to you by going to your device settings and selecting “Limit Ad Tracking” (for iOS devices) or “Opt Out of Interest-Based Ads” (for Android devices). Please note that if you opt out using any of these methods, the opt out will only apply to the specific browser or device from which you opt out. We are not responsible for the effectiveness of, or compliance with, any opt out options or programs, or the accuracy of any other entities’ statements regarding their opt out options or programs. C. Right to Know Under Applicable State Laws, you have the right to know certain information about our data practices. For example, California residents have the right to request the following from us: The categories and specific pieces of personal information that have been collected by Shift1Up; The categories of sources from which the personal information was collected; The categories of third parties with whom personal information is shared; The categories of information that are sold or disclosed for a business purpose to third parties; and The business or commercial purpose for collecting or selling personal information. Under applicable law you may have the right to receive this information in a portable, and to the extent technically feasible, readily usable format. D. Right to Delete Your Personal Information Under Applicable State Laws, you may have the right to request that we delete your personal information. This right to deletion does not apply to any of your personal information that is subject to an exception under Applicable State Laws. Once we receive your request and verify your identity, we will delete all personal information in our records that is not subject to a legal exception. E: Right to Correct Inaccurate Personal Information Under Applicable State Laws, you may have the right to request the correction of personal information where it is inaccurate or incomplete. In some cases, we may provide self-service tools that enable you to manually update your personal information. F. Right to Appeal You may have the right to appeal our decision or response to your request. To exercise your right to appeal, you can submit an appeal request using the same method used to submit your original request, including by contacting us as set forth in “Contact Us” below. G. Right to Limit Sharing of Your Sensitive Personal Information Under Applicable State Laws, you may have the right to limit our use and disclosure of certain “sensitive” personal information. Examples of sensitive personal information we process include your social security number, driver’s license number, precise geolocation, and health-related information. The right to limit the processing of sensitive personal information only applies if the information is processed for purposes of inferring characteristics about you. Shift1Up currently does not engage in such processing. H. Right to Limit Profiling Under Applicable State Laws, you may also have the right to limit our use and disclosure of personal information for profiling. Please note that this right only applies to the extent that such profiling is carried out in furtherance of decisions that produce legal or similarly significant effects concerning you. I. Exercising Your Rights To exercise any of these rights, email us at [contact@shift1up.com]. In the request, please specify which right you are seeking to exercise and the scope of the request. We will confirm receipt of your request within 10 days. In order to verify your identity and process your request, we may ask you to provide certain information so that we can match that data to you in our systems. If we are unable to verify your identity, we may deny your request to know, correct, or delete. J. Authorized Agent You can designate an authorized agent to submit requests on your behalf. However, we will require written proof of the agent’s permission to do so and verify your identity directly. K. Right to Non-Discrimination You have the right not to receive discriminatory treatment by Shift1Up for the exercise of any of your rights. L. Shine the Light Customers who are residents of California may request (i) a list of the categories of personal information disclosed by us to third parties during the immediately preceding calendar year for those third parties’ own direct marketing purposes; and (ii) a list of the categories of third parties to whom we disclosed such information. To exercise a request, please write us at the email or postal address set out in “Contact Us” below and specify that you are making a “California Shine the Light Request.” We may require additional information from you to allow us to verify your identity and are only required to respond to requests once during any calendar year. 10. Children’s Information Our Services are not directed to children under 13 (or other age as required by local law), and we do not knowingly collect personal information from children. If you are a parent or guardian and believe your child has uploaded personal information to our Services without your consent, you may contact us as described in “Contact Us” below. If we become aware that a child has provided us with personal information in violation of applicable law, we will delete any personal information we have collected, unless we have a legal obligation to keep it. 11. Third-Party Websites/Applications The Services may contain links to other websites/applications and other websites/applications may reference or link to our Site. These third-party sites are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen, or approve, and are not responsible for, the privacy practices or content of such other websites or applications. Providing personal information to third-party websites or applications is at your own risk. 12. Contact Us Shift1Up is the controller of the personal information we process under this Privacy Policy. If you have any questions about our privacy practices or this Privacy Policy, or to exercise your rights as detailed above, please contact us at: Shift1Up [5830 E 2nd St, Ste 7000 #33654] [Casper, Wyoming, 82609] [contact@shift1up.com] [1-219-400-4599] 5830 E 2nd St, Ste 7000 #33654 Casper, Wyoming 82609 US Shift1Up LLC · 5830 E 2nd St, Ste 7000 #33654, Casper, Wyoming 82609 US contact@shift1up.com · +1 (219) 400-4599 · www.shift1up.com © 2026 Shift1Up LLC. All rights reserved.