OfferMile PRIVACY POLICY

Last Updated: September 29, 2026

This Privacy Policy explains how Jan Logistical Services LLC d/b/a OfferMile ("OfferMile," "we," "us") collects, uses, discloses, and protects information in connection with the OfferMile marketplace (the "Platform"). Capitalized terms not defined here have the meanings in the Marketplace Terms of Service.

The Platform is offered only to businesses. Most personal information we process relates to individuals acting for Members (owners, officers, Authorized Users, inspectors) and to drivers designated by Renters.

1. Information We Collect

1.1 Business and KYB Information

Legal name, DBA, EIN, formation documents, addresses, USDOT/MC numbers, FMCSA registration and safety data, Shipper Program disclosures (optional), bank account details (processed by Stripe), and beneficial owner and control-person information (name, date of birth, address, last four digits of SSN or ID number, government ID images) required for identity verification and anti-fraud/sanctions screening.

1.2 Account and Authorized User Information

Names, job titles, business email and phone, login credentials, multi-factor data, roles, and activity logs.

1.3 Authorized Driver Information

Provided by the Renter: driver name, license number, issuing state, expiration, date of birth, license image, and the Renter's certification of qualification. We do not request MVRs, medical certificates, or background reports from Renters, and Renters should not upload them unless we expressly request a specific document for a specific purpose. If we later offer MVR screening, we will do so through a consumer reporting agency under the Fair Credit Reporting Act with separate disclosures and written authorization from the driver, and with adverse-action procedures as required.

1.4 Rental and Transaction Information

Listings, Vehicle data (VIN, plate, maintenance and inspection records, recall status), Bookings, Rental Documents, e-signature audit data (name, timestamp, IP address, device, document hash), payment history, Claims, messages, ratings, and COIs and insurance details.

1.5 Inspection Photos and Metadata

VCR photographs and video (which may incidentally capture people, license plates, or locations), with timestamps, device identifiers, and GPS coordinates where permitted by the device.

1.6 Telematics and Vehicle Data

The Platform does not itself operate Telematics Devices. However, we may receive Vehicle data that Members choose to upload or connect (e.g., odometer, location at pickup/return, diagnostic codes, or telematics excerpts submitted as Claim evidence), and Members may connect third-party telematics providers (e.g., Samsara, Geotab) through integrations they authorize. Telematics data may include location history, speed, and driver-behavior events, and in some systems driver-facing video or audio. Owners and Renters are independently responsible for their own Telematics Devices and the data those devices collect, including required notices to and consents from drivers (MVRA Section 17).

1.7 Payment Information

Card and bank details are collected directly by Stripe; we receive limited information (card brand, last four digits, expiration, bank last four, mandate identifiers, payment status).

1.8 Technical and Usage Information

IP address, device and browser data, cookies and similar technologies, pages viewed, and log data.

1.9 Public and Third-Party Sources

FMCSA SAFER/L&I/SMS data, Secretary of State records, sanctions lists, NHTSA recall data, identity-verification providers, insurance agents confirming coverage, and toll or citation notices submitted by Owners.

2. How We Use Information

We use information to: (a) create and administer Accounts and verify businesses and their owners (KYB/KYC, fraud prevention, sanctions screening); (b) operate the marketplace, including search, Bookings, Owner-anonymity controls, and Owner Identity disclosure after Booking; (c) generate, execute, and store Rental Documents and VCRs; (d) process payments and Payouts through Stripe, including recurring charges and Security Deposits; (e) verify and monitor insurance and regulatory status; (f) administer Claims and disputes, including reviewing messages, photos, and Vehicle data submitted as evidence; (g) enforce the Platform Documents (including anti-circumvention); (h) send transactional communications (renewal receipts, insurance alerts, recall notices); (i) comply with legal obligations (tax reporting such as Form 1099-K, law-enforcement requests, and record retention); (j) improve and secure the Platform; and (k) with consent where required, send marketing communications about Platform features.

We do not sell personal information and do not use driver information for advertising.

3. How We Disclose Information

3.1 Between Members. Before Booking, Owner Identity is withheld from Renters. After Booking Confirmation, we disclose to the counterparty the information needed to perform the Rental: legal names, addresses, USDOT numbers, contact persons, Authorized Driver names and license details (to Owners, for handover verification), insurance details, VCRs, and Claims evidence.

3.2 Service Providers. Hosting, e-signature, identity verification, communications, customer support, analytics, and security vendors, under contracts restricting their use of the data.

3.3 Stripe. When you provide personal data in connection with payments on the Platform, Stripe receives that personal data and processes it in accordance with Stripe's Privacy Policy (https://stripe.com/privacy). We share KYB and transaction information with Stripe as described in the Terms (Section 11).

3.4 Insurers and Claims. Insurers, agents, adjusters, and appraisers of the Owner or Renter in connection with a Claim or accident, upon request of a party or as reasonably necessary.

3.5 Legal and Safety. Law enforcement, regulators (including FMCSA and state agencies), toll and citation authorities (e.g., to transfer responsibility for a violation to the Renter), and courts or arbitrators, when required by law, to respond to legal process, to protect rights and safety, or where a rental agreement requires cooperation with law enforcement to identify the operator of a rental CMV.

3.6 Corporate Transactions. In connection with a merger, financing, acquisition, or sale of assets, subject to confidentiality.

3.7 Aggregated / De-identified Data. For benchmarks and analytics that do not identify any Member or individual.

4. Driver Privacy

4.1 Renters provide driver information to us and to Owners. Renters are responsible for providing drivers with any notice required by law regarding this sharing, and for obtaining FCRA-compliant disclosures and authorizations when they obtain MVRs through consumer reporting agencies.

4.2 Owners must use driver information only to verify identity at handover, administer the Rental, and handle Claims or Violations, and must not retain it longer than needed for those purposes and legal retention obligations.

4.3 Driver license numbers are displayed only in masked form except where needed for verification.

4.4 Telematics. Owners may access telematics data during a Rental only for the limited purposes in MVRA Section 17.3, and not driver-facing video or audio except to investigate an accident, theft, or Claim or with Renter consent.

5. Stripe and Payment Data

Payment card data is handled by Stripe, which is certified as a PCI DSS Level 1 service provider verify at time of publication. We do not store full card numbers or bank account numbers.

6. Data Retention

7. Security

We use administrative, technical, and physical safeguards appropriate to the sensitivity of the data, including encryption in transit and at rest, role-based access, multi-factor authentication, audit logging, and tamper-evident storage of signed records. No system is completely secure. We will notify affected Members and individuals of security breaches as required by applicable state breach-notification laws.

8. Your Choices and Rights

8.1 Members may access and update Account information, download Rental Documents, and manage Authorized Users and drivers in the Platform.

8.2 Individuals may request access to, correction of, or deletion of their personal information by emailing privacy@offermile.com. We may need to retain information as described in Section 6 or where required by law, and may deny requests where permitted.

8.3 State Privacy Laws. Several U.S. state comprehensive privacy laws exclude or limit coverage of personal information collected in a business-to-business or employment context; others (notably California) apply to B2B and employee data. To the extent any such law applies, we will honor applicable rights (e.g., access, deletion, correction, opt-out of sale/sharing — we do not sell or share for cross-context advertising), and will not discriminate against individuals for exercising them.

8.4 Marketing. You may unsubscribe from marketing emails at any time; transactional messages will continue.

8.5 Cookies. You can control cookies through your browser; see our Cookie Notice link for details.

9. Children

The Platform is not directed to individuals under 18, and we do not knowingly collect their information.

10. International Users

The Platform is intended for U.S. businesses; information is stored and processed in the United States.

11. Changes

We may update this Privacy Policy and will notify Members of material changes by email or in-Platform notice before they take effect.

12. Contact

Jan Logistical Services LLC · Attn: Privacy · privacy@offermile.com