PUBLISHED PUBLIC POLICY

PRIVACY POLICY

Effective Date: 2026-09-30

This Privacy Policy (the “Policy”) describes how Wheelson Auto Inc., having its business address at 329 Linden Ave., Woodlynne, New Jersey 08107 (hereinafter the “Company”) collects, uses, stores, discloses, and otherwise handles Personal Information in connection with the Company’s Platform, Platform Services, rental applications, vehicle rental relationships, payment and transaction administration, customer communications, and related business activities.

This Policy applies to Customers and other individuals whose Personal Information is collected or handled by the Company in connection with those activities. It should be read together with the Company’s Platform Terms and Conditions and, where applicable, the relevant Rental Agreement, Rental Schedule, GPS and Vehicle Tracking Consent, payment authorization, and any other document governing a particular transaction or service.

This Policy explains the Company’s privacy and data practices. It does not replace or modify the commercial or operational terms of a Rental Agreement, Rental Schedule, or other separately applicable agreement, authorization, consent, or acknowledgment. Where applicable law imposes a requirement concerning the handling of Personal Information that cannot lawfully be modified by this Policy, that requirement shall control.

Article 1. DEFINITIONS

1.1. For purposes of this Policy, the following words and expressions shall have the meanings set out below whenever they are used with an initial capital letter. Defined terms may be used in the singular or plural as the context requires.

a. “Company” means Wheelson Auto Inc., with its business address at 329 Linden Ave., Woodlynne, New Jersey 08107, as the entity responsible for the privacy practices described in this Policy.

b. “Customer” means an individual who interacts with the Company in connection with the Platform, Platform Services, a rental inquiry or application, an existing or proposed vehicle rental, or another service or transaction offered or administered by the Company.

c. “Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked with a particular individual or household, and includes other information treated as personal information, personal data, or a similar protected category under applicable law. Personal Information does not include information lawfully excluded from such definitions under applicable law.

d. “Platform” means the website, application, electronic portal, customer account system, or other electronic interface designated by the Company through which Customers may access or use Platform Services.

e. “Platform Services” means the electronic functions and services made available by the Company through the Platform, which may include rental applications, customer account administration, access to vehicle or transaction information, electronic contracting, document delivery, payment functionality, communications, records, and other administrative functions.

f. “Processing” means any operation performed on Personal Information, including its collection, access, use, organization, storage, review, transmission, disclosure, correction, retention, deletion, or other handling.

g. “Rental Agreement” means the separate vehicle rental agreement entered into between the Company and a Customer governing the Customer’s possession and use of a particular Vehicle, including the Long-Term Vehicle Rental Agreement with Optional Purchase Opportunity where that agreement applies.

h. “Rental Schedule” means the transaction specific schedule issued in connection with a Rental Agreement that identifies the particular Vehicle and the applicable commercial terms of that rental transaction.

i. “Rental Transaction” means a proposed, pending, active, or completed vehicle rental relationship or related transaction between the Company and a Customer, including the application, administration, payment, return, and other activities reasonably associated with that relationship.

j. “Third-Party Service Provider” means an independent person or entity whose technology, services, systems, or infrastructure is used by or on behalf of the Company to support its operations or provide services in connection with the Platform, Platform Services, or a Rental Transaction, including payment processing, electronic contracting, identity or information verification, communications, hosting, data storage, mapping, or similar supporting functions.

k. “Tracking Data” means location, movement, route, position, date and time, or similar information generated, collected, or transmitted through GPS, telematics, or other location enabled technology associated with a Vehicle, to the extent such information constitutes Personal Information.

l. “Vehicle Data” means information generated by, obtained from, or associated with a Vehicle or technology installed in or used with a Vehicle, which may include mileage, odometer information, operational status, diagnostic information, service or maintenance information, event information, and Tracking Data, to the extent such information is collected by or made available to the Company.

m. “Vehicle” means a motor vehicle offered, proposed, provided, or administered by the Company in connection with a Rental Transaction.

Article 2. SCOPE AND APPLICATION OF THIS PRIVACY POLICY

2.1. Application of Policy. This Policy applies to the Processing of Personal Information by or on behalf of the Company in connection with the Platform, Platform Services, a proposed or actual Rental Transaction, and other interactions between the Company and a Customer that relate to the Company’s vehicle rental or associated business activities.

2.2. Stages of the Customer Relationship. This Policy may apply before, during, and after a Rental Transaction. This includes circumstances in which an individual makes an inquiry, submits a rental application, uses the Platform or Platform Services, enters into or performs a Rental Agreement, communicates with the Company, completes a transaction, returns a Vehicle, or otherwise maintains a relationship with the Company for which Personal Information is reasonably required.

2.3. Platform and Non-Platform Interactions. This Policy applies to Personal Information handled through the Platform and to Personal Information provided or obtained through other Company approved methods, including in person interactions, telephone communications, email, text messages, electronic documents, payment processes, and records created in the ordinary administration of a Rental Transaction.

2.4. Relationship with Other Documents. This Policy governs the Company’s privacy and data practices. The Platform Terms and Conditions govern access to and use of the Platform, while the applicable Rental Agreement and Rental Schedule govern the substantive terms of a Rental Transaction. Separate authorizations, consents, acknowledgments, or disclosures may apply to particular Processing activities, including recurring or electronic payments and the collection or use of Tracking Data.

2.5. Separate Consents and Authorizations. Where applicable law or the nature of a particular Processing activity requires a separate consent, authorization, acknowledgment, or notice, this Policy does not replace that requirement. The Company may provide or obtain the applicable document separately, and that document shall govern the specific Processing activity it expressly addresses.

2.6. Information Outside the Scope of this Policy. This Policy does not govern information that is not Personal Information or information that applicable law excludes from applicable privacy protections. It also does not govern the independent privacy practices of a third party acting for its own purposes rather than Processing Personal Information by or on behalf of the Company, except to the extent the Company has obligations concerning that third party under applicable law.

Article 3. PERSONAL INFORMATION WE COLLECT

3.1. General. The Personal Information collected by the Company depends on the nature of the Customer’s interaction with the Company, the Platform Services used, the stage of a Rental Transaction, and the information reasonably required to administer the applicable relationship. The Company may collect the categories of Personal Information described in this Section where relevant to its operations and the particular Customer or Rental Transaction.

3.2. Identification and Contact Information. The Company may collect a Customer’s name, residential or mailing address, email address, telephone number, date of birth, signature, photograph, and other identification or contact information provided in connection with an inquiry, application, account, Rental Transaction, or other interaction with the Company.

3.3. Driver and Identity Verification Information. The Company may collect information contained in or associated with a driver’s license or other identification document, including the issuing jurisdiction, license or document number, expiration date, driving eligibility information, and copies or images of identification documents where reasonably required. The Company may also collect information necessary to verify a Customer’s identity, driving eligibility, or information submitted in connection with a proposed or existing Rental Transaction.

3.4. Rental Application and Eligibility Information. When a Customer applies for or seeks to maintain a Rental Transaction, the Company may collect information submitted in the application or reasonably required to evaluate or document eligibility. This may include residential information, employment or income related information where requested, references or other contact information supplied by the Customer, application responses, verification results, and records concerning the status or outcome of the application.

3.5. Insurance Information. The Company may collect information relating to insurance coverage applicable to a Customer, authorized driver, or Vehicle, including the insurer’s name, policy number, coverage period, coverage status, insurance identification or proof of coverage, and information concerning changes, cancellation, expiration, or verification of coverage.

3.6. Payment and Transaction Information. The Company may collect information relating to payments and financial transactions associated with the Platform Services or a Rental Transaction, including billing information, payment amounts, payment dates, transaction identifiers, payment status, payment history, refunds, reversals, declined or failed payments, chargebacks, disputes, authorizations, and related account records. Where payments are processed through a Third-Party Service Provider, the Company may receive limited payment related information from that provider rather than the complete payment card, bank account, or other financial credentials used to complete the transaction.

3.7. Rental and Vehicle Administration Information. The Company may collect records relating to the administration and performance of a Rental Transaction, including the applicable Rental Agreement and Rental Schedule, Vehicle assignment, rental commencement and return information, mileage and odometer readings, inspection and condition records, maintenance and service records, Vehicle Swap records, payment status, amounts charged or outstanding, tolls, tickets, parking or traffic related notices, recovery or return records, and other information reasonably generated in administering the Rental Transaction.

3.8. Accident, Damage, Claim and Incident Information. If a Vehicle is involved in an accident, theft, loss, damage, breakdown, traffic incident, insurance claim, or other material event, the Company may collect information relating to the event, including the date and location, descriptions of what occurred, photographs or videos, police or incident reports where available, claim information, repair information, information concerning other persons or vehicles involved, witness information where provided, and communications or records associated with the event.

3.9. Communications and Customer Service Information. The Company may collect and maintain communications between the Customer and the Company, including email, text messages, telephone related records where lawfully maintained, Platform messages, inquiries, requests, complaints, notices, support communications, documents submitted by the Customer, and records of the Company’s responses or other communications concerning the Customer or a Rental Transaction.

3.10. Platform, Device and Technical Information. When a Customer accesses or uses the Platform or Platform Services, the Company or its Third-Party Service Providers may collect technical and usage information associated with that interaction. Depending on the technology used, this may include internet protocol address, device or browser information, operating system information, login and access information, date and time of access, pages or functions accessed, system activity, error or diagnostic information, and other technical information generated through use of the Platform.

3.11. Vehicle Data and Tracking Data. Where a Vehicle is equipped with GPS, telematics, or other Vehicle technology and the collection is permitted under applicable law and the applicable rental documentation, the Company may collect Vehicle Data and Tracking Data. Such information may include the Vehicle’s location, movement, route or position, mileage, odometer information, date and time information, operational or diagnostic information, and information concerning the status or functioning of Vehicle related technology. Additional information concerning the Processing of Vehicle Data and Tracking Data is provided in Section 6 of this Policy and, where applicable, in the separate GPS and Vehicle Tracking Consent.

3.12. Electronic Contracting and Records. The Company may collect information generated when a Customer reviews, accepts, signs, or otherwise interacts with an electronic document or transaction. This may include electronic signatures, acknowledgments, acceptance records, document versions, date and time records, transaction or audit records, delivery or access confirmations, and other information reasonably generated by an electronic contracting or recordkeeping system.

3.13. Information Concerning Other Persons. A Customer may provide Personal Information concerning another person where relevant to a Rental Transaction, including an authorized driver, emergency or other contact, reference, witness, passenger, insurance representative, or person involved in an accident, claim, or other Vehicle related incident. The Company may collect such information to the extent reasonably relevant to the applicable interaction or Rental Transaction.

3.14. Other Information Provided to the Company. The Company may collect other Personal Information that a Customer voluntarily provides or that is reasonably generated through the Customer’s dealings with the Company, provided that the information is relevant to the Platform Services, a Rental Transaction, the administration of the Company’s relationship with the Customer, or another legitimate business activity described in this Policy.

Article 4. SOURCES OF PERSONAL INFORMATION

4.1. Information Provided Directly by the Customer. The Company may obtain Personal Information directly from a Customer when the Customer communicates or interacts with the Company, creates or uses an account, submits an inquiry or rental application, provides documents or information, enters into or administers a Rental Transaction, makes or authorizes a payment, reports an accident or other incident, requests assistance, or otherwise provides information in connection with the Company’s business activities.

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4.2. Information Generated Through the Platform and Platform Services. The Company may obtain Personal Information through a Customer’s access to or use of the Platform and Platform Services, including information generated through account activity, electronic contracting, payment activity, communications, document access, transaction records, and technical interactions with the Platform. Certain information may be generated automatically by the systems or technologies used to provide the Platform Services.

4.3. Information Generated Through a Vehicle. Where applicable to a Rental Transaction and permitted by applicable law and the applicable rental documentation, the Company may obtain Vehicle Data and Tracking Data from a Vehicle, from technology installed in or associated with a Vehicle, or from systems used to receive or administer such information. The collection and Processing of Vehicle Data and Tracking Data are addressed further in Section 6 of this Policy and, where applicable, in the separate GPS and Vehicle Tracking Consent.

4.4. Information from Third Party Service Providers. The Company may receive Personal Information from Third Party Service Providers that support the Platform, Platform Services, or Rental Transactions. Depending on the services involved, these sources may include providers supporting payment processing, electronic contracting, identity or information verification, communications, hosting, data storage, mapping, or other operational functions used by the Company.

4.5. Information from Insurers, Claims Participants and Other Transaction Related Sources. Where relevant to a Rental Transaction, the Company may receive Personal Information from insurers, insurance representatives, repair or service providers, law enforcement or governmental authorities, persons involved in an accident or other Vehicle related incident, authorized drivers, references or contacts identified by a Customer, and other persons or entities reasonably involved in administering or documenting a transaction, claim, Vehicle related matter, or legal obligation.

4.6. Information from Public or Lawfully Available Sources. Where reasonably necessary for the Company’s operations and permitted by applicable law, the Company may obtain Personal Information from public records, governmental records or databases, or other sources from which the information is lawfully available.

4.7. Combined Information. The Company may combine Personal Information obtained from different sources where reasonably necessary to administer the Customer relationship, maintain accurate records, support a Rental Transaction, or otherwise carry out the purposes described in this Policy. Personal Information combined in this manner remains subject to this Policy to the extent the combined information is treated as Personal Information under applicable law.

Article 5. HOW WE USE PERSONAL INFORMATION

5.1. General Processing Purposes. The Company may Process Personal Information where reasonably necessary to provide the Platform Services, evaluate and administer Rental Transactions, perform its contractual and business obligations, protect its legitimate interests and legal rights, comply with applicable legal requirements, and carry out the other purposes described in this Policy. The particular purposes applicable to Personal Information will depend on the Customer’s interaction with the Company and the nature and stage of the relevant Rental Transaction.

5.2. Rental Applications and Eligibility. The Company may use Personal Information to receive and review rental inquiries and applications, verify identity and information submitted by a Customer, assess whether applicable rental requirements have been satisfied, confirm driving and insurance related eligibility where relevant, communicate concerning an application, and determine whether to enter into or continue a Rental Transaction.

5.3. Rental Transaction Administration. The Company may use Personal Information to prepare, enter into, administer, document, and enforce a Rental Agreement and Rental Schedule; assign and deliver a Vehicle; maintain transaction records; administer rental periods, Vehicle Swaps, returns, and other changes affecting a Rental Transaction; determine amounts due; and otherwise manage the contractual relationship between the Company and the Customer.

5.4. Payments and Account Administration. The Company may use Personal Information to process or facilitate authorized payments, maintain payment and account records, issue or provide transaction confirmations and receipts, identify unpaid or outstanding amounts, administer refunds or adjustments where applicable, address failed or declined payments, investigate payment discrepancies, respond to chargebacks or payment disputes, and reconcile the Customer’s account.

5.5. Vehicle Administration, Maintenance and Protection. The Company may use Personal Information to administer Vehicles made available through Rental Transactions, maintain Vehicle condition and mileage records, coordinate or document inspections, maintenance and repairs, investigate reported Vehicle issues, administer Vehicle returns or lawful recovery where applicable, protect Company property, and maintain records concerning the condition, possession, use, servicing, or return of a Vehicle.

5.6. Vehicle Data and Tracking Data. Where permitted by applicable law and the applicable rental documentation, the Company may Process Vehicle Data and Tracking Data for purposes reasonably connected with Vehicle administration, security, location and recovery, mileage or usage administration, maintenance, investigation of suspected misuse or unauthorized activity, response to emergencies or reported incidents, and protection of the Company’s Vehicles and legal rights. Section 6 provides additional information concerning the Processing of Vehicle Data and Tracking Data.

5.7. Insurance, Accidents, Damage and Claims. The Company may use Personal Information to verify or administer applicable insurance information, document and respond to accidents, theft, loss, damage or other Vehicle related incidents, communicate with persons reasonably involved in an incident or claim, evaluate or document responsibility and loss, support insurance or repair processes, and establish, exercise, or defend claims and legal rights.

5.8. Tolls, Tickets and Other Vehicle Related Charges. The Company may use Personal Information to identify, verify, administer, allocate, or dispute tolls, parking charges, traffic or camera violations, governmental charges, towing or recovery expenses, and other Vehicle related amounts associated with a Rental Transaction, and to maintain records concerning their payment or resolution.

5.9. Customer Communications and Service. The Company may use Personal Information to communicate with a Customer concerning an inquiry, application, account, Rental Transaction, payment, Vehicle, document, notice, request, complaint, dispute, or other service-related matter; respond to questions or requests; provide transaction related information; and maintain appropriate records of those communications.

5.10. Electronic Contracting and Recordkeeping. The Company may use Personal Information to prepare, deliver, execute, authenticate, store, and maintain electronic agreements, authorizations, consents, acknowledgments, notices, receipts, and other transaction records, and to establish or verify the date, time, version, delivery, acceptance, or execution of an electronic record where relevant.

5.11. Security, Fraud Prevention and Misuse. The Company may use Personal Information to protect the Platform, Platform Services, Customers, Vehicles, Company property, accounts, transactions, and records; verify identity or transaction activity; detect, investigate, prevent, or respond to suspected fraud, misrepresentation, unauthorized access, misuse, theft, tampering, false payment disputes, or other unlawful or unauthorized conduct; and maintain the security and integrity of the Company’s operations.

5.12. Legal and Regulatory Purposes. The Company may use Personal Information to comply with applicable laws, regulations, court orders, subpoenas, governmental requests, recordkeeping requirements, and other legal obligations; respond to lawful requests from public authorities; cooperate with legal or regulatory proceedings where required or permitted; and establish, exercise, protect, or defend the Company’s legal rights and interests.

5.13. Internal Business Administration and Service Improvement. The Company may use Personal Information as reasonably necessary for internal administration, accounting, auditing, record management, operational review, troubleshooting, service quality, Platform functionality, business planning, and improvement of the Company’s services and administrative processes. Where reasonably practicable for a particular internal purpose, the Company may use information in an aggregated or deidentified form.

5.14. Other Purposes and Required Consent. The Company may Process Personal Information for another purpose that is reasonably compatible with the purpose for which the information was collected and permitted by applicable law. Where applicable law requires notice, consent, authorization, or another legal basis before Personal Information may be Processed for a materially different purpose, the Company will provide or obtain the applicable notice, consent, authorization, or other basis before undertaking that Processing.

Article 6. VEHICLE DATA, LOCATION INFORMATION AND TRACKING

6.1. Vehicle Technology. A Vehicle may be equipped with GPS, telematics, diagnostic systems, or other technology capable of generating or transmitting Vehicle Data or Tracking Data. The availability and functionality of such technology may vary by Vehicle, equipment, service provider, and system configuration. The Company will Process information obtained through such technology only to the extent reasonably connected with its business activities and permitted by applicable law and the applicable rental documentation.

6.2. Location and Movement Information. Where applicable tracking technology is installed or active, Tracking Data may provide information concerning the location, movement, route, position, or use of a Vehicle during a Rental Transaction. Depending on the technology involved, this information may be generated periodically, in response to particular events or requests, or through other system functionality available in connection with the Vehicle.

6.3. Relationship with GPS and Vehicle Tracking Consent. Where the Company uses GPS or other tracking technology in circumstances for which separate notice, acknowledgment, or consent is required or obtained, the applicable GPS and Vehicle Tracking Consent shall provide additional information concerning that technology and the Customer’s acknowledgment or authorization. This Policy describes the Company’s privacy practices concerning Tracking Data and does not replace any separate consent or authorization required by applicable law.

6.4. Access to Vehicle Data and Tracking Data. Access to Vehicle Data and Tracking Data within the Company shall be limited to persons who reasonably require the information for an authorized business, operational, security, administrative, claims related, or legal purpose. The Company may also permit a Third-Party Service Provider to Process such information where reasonably necessary to provide or support the applicable technology or related services.

6.5. Disclosure of Vehicle Data and Tracking Data. The Company may disclose Vehicle Data or Tracking Data where reasonably necessary to administer a Rental Transaction, locate, protect, return, or lawfully recover a Vehicle, investigate suspected unauthorized use, concealment, abandonment, theft, loss, failure to return, or other Vehicle-related incidents, address an accident, claim, emergency, or safety matter, comply with a lawful request or legal obligation, protect the rights, property, or safety of the Company or others, or otherwise as permitted by Applicable Law. Where circumstances reasonably warrant a report, investigation, or request for assistance concerning suspected theft or other unlawful conduct involving a Vehicle, the Company may disclose relevant Vehicle Data or Tracking Data to an appropriate law enforcement or governmental authority to the extent reasonably necessary and permitted by Applicable Law. Nothing in this Policy determines whether particular conduct constitutes theft or another criminal offense, and any such determination shall be made under Applicable Law by the appropriate authorities. Any disclosure to a Third-Party Service Provider or other recipient remains subject to the applicable principles described in Section 7 of this Policy.

6.6. Tracking and Customer Devices. Vehicle tracking described in this Policy concerns technology associated with or used in connection with a Vehicle. Nothing in this Policy should be interpreted as stating that the Company continuously tracks the independent location of a Customer’s personal mobile telephone or other personal device unless such functionality is separately disclosed and lawfully implemented through the Platform or another Company service.

6.7. Retention and Security. Vehicle Data and Tracking Data will be retained in accordance with the principles described in Section 11 and protected in accordance with the measures described in Section 12. The duration for which particular information remains available may also depend on the technology or Third-Party Service Provider through which the information is generated, transmitted, or maintained.

6.8. Legal Requirements and Limitations. The collection, use, access, retention, and disclosure of Vehicle Data and Tracking Data shall remain subject to applicable law and any mandatory requirements applicable to the particular Processing activity.

Article 7. HOW AND WHEN WE DISCLOSE PERSONAL INFORMATION

7.1. General. The Company may disclose Personal Information where reasonably necessary to operate its business, provide the Platform Services, administer a Rental Transaction, perform or enforce applicable agreements, protect Vehicles and other Company property, address claims or disputes, comply with legal requirements, or carry out another purpose described in this Policy. The Company will limit disclosures to information reasonably relevant to the purpose for which the disclosure is made, subject to applicable law.

7.2. Third Party Service Providers. The Company may disclose Personal Information to Third Party Service Providers that perform or support functions on behalf of the Company or provide technology or infrastructure used in connection with the Platform, Platform Services, or Rental Transactions. These functions may include payment processing, electronic contracting, identity or information verification, communications, hosting, data storage, mapping, technical support, security, recordkeeping, and other operational services. Section 8 provides additional information concerning the Company’s use of Third-Party Service Providers.

7.3. Payment and Financial Service Providers. Personal Information may be disclosed to payment processors, financial institutions, payment networks, card networks, Platform providers, fraud prevention providers, or other persons or entities involved in processing, authorizing, settling, recording, reversing, refunding, investigating, or disputing a payment associated with the Company or a Rental Transaction. Where reasonably necessary to investigate, respond to, document, or defend a payment dispute, chargeback, reversal, suspected payment fraud, or similar transaction matter, the Company may disclose relevant payment records, transaction information, authorizations, electronic contracting and acceptance records, communications, receipts, and other Rental Transaction records reasonably relevant to establishing the nature, authorization, or validity of the transaction. The information disclosed shall be limited to information reasonably relevant to the applicable payment, transaction, dispute, or service and shall remain subject to Applicable Law.

7.4. Insurance, Claims, Repairs and Vehicle Related Matters. Where reasonably necessary in connection with an accident, damage, theft, loss, insurance matter, repair, maintenance issue, Vehicle recovery, or other Vehicle related incident, the Company may disclose Personal Information to insurers, insurance representatives, claims administrators, repair or service providers, towing or recovery providers, persons involved in an incident, and other persons or entities reasonably necessary to investigate, document, administer, resolve, or protect the Company’s interests in the matter.

7.5. Tolls, Tickets, Violations and Government Charges. The Company may disclose Personal Information where reasonably necessary to identify, administer, contest, transfer, respond to, or resolve tolls, parking charges, traffic or camera violations, citations, governmental charges, or similar matters associated with a Vehicle or Rental Transaction, including disclosures to the relevant governmental authority, tolling authority, administrator, or other entity responsible for the matter.

7.6. Optional Purchase and Vehicle Transfer Transactions. If a Customer becomes eligible for and elects to proceed with an Optional Purchase Opportunity under the applicable Rental Agreement, the Company may disclose Personal Information reasonably necessary to evaluate, document, administer, or complete the proposed sale, title transfer, registration, or related transaction. Where a licensed motor vehicle dealer, title or registration service, governmental agency, or other person or entity is lawfully required or reasonably necessary to complete the transaction, relevant Personal Information may be provided to that person or entity for that limited purpose. This may include disclosure to AUTO MAX FJ INC. where that entity is involved in completing the applicable purchase or transfer transaction.

7.7. Professional Advisers and Business Support. The Company may disclose Personal Information to attorneys, accountants, auditors, tax professionals, consultants, insurers, and other professional advisers where reasonably necessary for legal advice, accounting, auditing, tax, insurance, compliance, dispute resolution, risk management, or other legitimate professional services provided to the Company.

7.8. Legal, Regulatory and Governmental Disclosures. The Company may disclose Personal Information where required or permitted by applicable law, regulation, legal process, court order, subpoena, warrant, or lawful governmental request. The Company may also disclose Personal Information where reasonably necessary to cooperate with a lawful investigation, respond to a governmental or regulatory authority, comply with legal obligations, or establish, exercise, protect, or defend legal rights.

7.9. Safety, Fraud and Protection of Rights. The Company may disclose Personal Information where reasonably and lawfully necessary to investigate or respond to suspected fraud, theft, misrepresentation, unauthorized use, security incidents, threats to persons or property, or other unlawful or harmful conduct, or to protect the rights, safety, property, Vehicles, systems, Customers, or legitimate interests of the Company or another person.

7.10. Business Transactions and Organizational Changes. Personal Information may be disclosed in connection with an actual or proposed merger, acquisition, financing, sale of assets, reorganization, restructuring, change of control, or similar business transaction involving all or part of the Company’s business, subject to appropriate confidentiality, privacy, and legal requirements applicable to the transaction.

7.11. Disclosures Authorized or Directed by the Customer. The Company may disclose Personal Information where a Customer requests, directs, or authorizes the disclosure, including where the Customer asks the Company to communicate or provide information to another person in connection with a Rental Transaction. Where applicable law requires a particular form of consent or authorization for the disclosure, the Company may require that form before releasing the information.

7.12. Other Disclosures Permitted by Law. The Company may make another disclosure of Personal Information where the disclosure is reasonably connected with the purposes described in this Policy and is permitted by applicable law. Where applicable law requires additional notice, consent, authorization, or another condition before a particular disclosure may be made, the Company will comply with that requirement to the extent applicable.

Article 8. THIRD PARTY SERVICE PROVIDERS

8.1. Use of Third-Party Service Providers. The Company may use Third Party Service Providers to provide technology, infrastructure, professional support, or operational functions that assist the Company in operating the Platform, providing Platform Services, administering Rental Transactions, maintaining records, communicating with Customers, protecting its systems and Vehicles, and conducting its business. The Company’s use of a Third-Party Service Provider does not, by itself, change the Company’s responsibilities for its own Processing of Personal Information under this Policy or applicable law.

8.2. Processing on Behalf of the Company. Where a Third-Party Service Provider Processes Personal Information on behalf of the Company, the Company may provide or permit access to Personal Information reasonably necessary for the provider to perform the applicable services. The Company will use reasonable measures appropriate to the nature of the services and information involved to require such providers to handle Personal Information consistently with their contractual obligations and applicable law.

8.3. Provider Systems and Infrastructure. Certain Platform Services or business functions may depend on systems, software, networks, storage, communications infrastructure, or other technology operated by a Third-Party Service Provider. As a result, Personal Information may be transmitted to, stored by, or otherwise Processed through systems that are not directly operated by the Company. The Company may rely on the security, availability, and technical functionality of those systems in providing the relevant services.

8.4. Independent Processing by Third Parties. In some circumstances, a third party that receives Personal Information in connection with the Company’s activities may determine independently how and why it Processes that information rather than Processing it solely on behalf of the Company. Where that occurs, the third party’s own privacy notice, terms, legal obligations, and data practices may apply to its independent Processing. Nothing in this Policy is intended to represent that the Company controls Processing undertaken independently by another person or entity.

8.5. Changes in Third Party Service Providers. The Company may engage, replace, or discontinue Third Party Service Providers as its operational or technological needs change. A change in provider does not, by itself, alter the purposes for which the Company Processes Personal Information under this Policy. Where a change materially affects the Company’s privacy practices or requires additional notice or consent under applicable law, the Company will address that requirement as applicable.

8.6. Independent Provider Practices. Where a Third-Party Service Provider Processes Personal Information independently rather than on behalf of the Company, the provider’s own privacy practices may apply as described further in Section 15.

Article 9. PAYMENT INFORMATION

9.1. Payment Processing. The Company may use Third Party Service Providers to process or facilitate payments associated with the Platform Services or a Rental Transaction. When a Customer provides a payment card, bank account, or other payment method through a payment service made available by the Company, some or all of the payment credentials may be provided directly to and Processed by the applicable Third-Party Service Provider rather than being received or stored in complete form by the Company.

9.2. Information Available to the Company. Depending on the payment method and provider involved, the Company may receive limited information concerning a Customer’s payment method together with transaction information necessary to administer the Customer’s account and Rental Transaction. Such information may include a payment method type, limited or masked account details, transaction identifiers, payment amounts and dates, authorization or payment status, and records of successful, failed, reversed, refunded, or disputed transactions. The Company does not represent that it receives or stores complete payment card or bank account credentials where those credentials are handled directly by a Third-Party Service Provider.

9.3. Recurring and Authorized Payments. Where a Customer separately authorizes recurring or other electronic payments, the Company and its applicable Third-Party Service Providers may Process information reasonably necessary to administer that authorization and the transactions made under it. The terms and scope of any recurring or electronic payment authorization are governed by the applicable Recurring and Electronic Payment Authorization or other payment authorization accepted by the Customer. This Policy describes the related privacy practices and does not itself constitute authorization to initiate a payment.

9.4. Payment Records. The Company may maintain records concerning payments and payment-related activity associated with a Customer or Rental Transaction, including transaction confirmations, receipts, payment status, refunds, reversals, failed or declined transactions, chargebacks, disputes, adjustments, and account reconciliation records. The Company may retain such records separately from the complete financial credentials used to initiate a payment.

9.5. Payment Disputes and Verification. Where a payment is disputed, reversed, declined, questioned, or otherwise requires verification, the Company may Process relevant Personal Information and transaction records for the purposes described in Section 5.4. Nothing in this Section limits a Customer’s right to raise a payment dispute in good faith where permitted by applicable law or the applicable payment arrangement.

9.6. Payment Security. The Company will use reasonable measures appropriate to the nature of the payment information within its possession or control. Payment information Processed directly through a Third-Party Service Provider may also be subject to that provider’s security practices, systems, terms, and privacy policies. The Company does not guarantee that any electronic payment system or method of transmission is completely secure.

9.7. Retention of Payment Information. Payment and transaction records will be retained in accordance with Section 11 of this Policy. The period for which payment credentials or related information are maintained by a Third-Party Service Provider may be determined by that provider’s services, legal obligations, and applicable policies where the information is processed independently of the Company.

Article 10. COOKIES AND SIMILAR TECHNOLOGIES

10.1. Use of Cookies and Similar Technologies. The Platform may use cookies and similar technologies where necessary or appropriate to provide, secure, maintain, or improve Platform functionality. Depending on the technology implemented, these technologies may store or retrieve information through a Customer’s browser or device and may generate technical information concerning the Customer’s interaction with the Platform.

10.2. Essential and Functional Technologies. The Company may use technologies that are reasonably necessary for the operation, security, or functionality of the Platform, including technologies used to maintain sessions, support account access, remember selections or settings, prevent unauthorized activity, maintain system security, or enable features requested by a Customer. Disabling such technologies may affect the availability or proper operation of certain Platform Services.

10.3. Performance and Analytics Technologies. To the extent implemented, the Company may use analytics or performance technologies to understand how the Platform is accessed and used, identify technical problems, evaluate system performance, and improve Platform functionality and user experience. Information obtained through such technologies may be Processed in an aggregated or deidentified form where reasonably practicable.

10.4. Advertising and Similar Tracking Technologies. If the Company implements advertising, targeted advertising, cross-context behavioral advertising, or similar tracking technologies, the Company will provide any disclosure, consent mechanism, or privacy choice required by applicable law.

10.5. Technologies Operated by Third Parties. Certain technologies used in connection with the Platform may be provided or operated by a Third-Party Service Provider. Where such a provider Processes Personal Information on behalf of the Company, the principles described in Section 8 apply. Where a third party independently determines its own Processing, its own privacy practices and notices may also apply.

10.6. Browser and Device Controls. A Customer may be able to manage certain cookies or similar technologies through browser, device, or Platform settings, where such controls are available. The effect of disabling or restricting a particular technology will depend on its function, and certain Platform Services may not operate properly if technologies necessary for their operation are disabled.

10.7. Consent and Legally Required Choices. Where applicable law requires consent, an opt-out mechanism, or another choice concerning a particular cookie or similar technology, the Company will provide or honor the applicable mechanism to the extent required. A Customer’s use of the Platform will not, by itself, be treated under this Policy as consent to a technology for which applicable law requires a separate form of consent.

Article 11. DATA RETENTION

11.1. General Retention Principle. The Company will retain Personal Information for as long as reasonably necessary to fulfill the purposes for which it was collected or subsequently Processed in accordance with this Policy, including to administer the Customer relationship and any Rental Transaction, maintain appropriate business and transaction records, comply with applicable legal obligations, resolve disputes, and establish, exercise, or defend legal rights.

11.2. Factors Affecting Retention. The period for which the Company retains particular Personal Information may vary depending on the nature and sensitivity of the information, the purpose for which it is Processed, the duration and status of the Customer relationship or Rental Transaction, applicable contractual requirements, reasonably anticipated or existing claims or disputes, fraud prevention and security considerations, applicable limitation periods, and legal, accounting, tax, regulatory, or recordkeeping requirements.

11.3. Active and Completed Rental Transactions. Personal Information reasonably necessary to administer an active Rental Transaction may be retained throughout that relationship. Following completion, termination, return, or recovery of a Vehicle, the Company may continue to retain relevant records where reasonably necessary for accounting, payment reconciliation, tolls or violations, insurance or claims administration, Vehicle condition or damage matters, dispute resolution, legal compliance, or protection of the Company’s legal rights.

11.4. Payment and Transaction Records. Payment, authorization, receipt, account, and transaction records may be retained for periods reasonably necessary for accounting, reconciliation, refunds, reversals, chargebacks, disputes, tax or financial recordkeeping, legal compliance, and the establishment or defense of claims. Complete payment credentials Processed independently by a Third-Party Service Provider may be subject to that provider’s separate retention practices and legal obligations, as described in Section 9.

11.5. Vehicle Data and Tracking Data. The Company will retain Vehicle Data and Tracking Data only for as long as reasonably necessary for the purposes for which the information is Processed, taking into account Vehicle administration, security, mileage or usage administration, maintenance, reported incidents, suspected unauthorized activity, lawful recovery, claims, disputes, and applicable legal requirements. The Company does not undertake through this Policy to retain Tracking Data for any fixed minimum or maximum period unless a particular period is required by applicable law, the applicable technology, or a separately disclosed Company practice.

11.6. Legal Holds, Claims and Investigations. Notwithstanding the Company’s ordinary retention practices, relevant Personal Information may be retained for a longer period where the Company reasonably determines that preservation is necessary in connection with pending or reasonably anticipated litigation, a claim, investigation, audit, governmental or regulatory matter, legal process, fraud or security investigation, or another circumstance requiring preservation of relevant records.

11.7. Information Maintained by Third Parties. Personal Information Processed through a Third-Party Service Provider may also be retained within systems operated by that provider. Where the provider Processes the information on behalf of the Company, the Company will address retention in a manner appropriate to the services and applicable legal requirements. Where a third-party Processes information independently, its own retention practices and legal obligations may apply.

11.8. Deletion, Deidentification and Disposal. When Personal Information is no longer reasonably necessary for the purposes for which it is retained and continued retention is not otherwise required or permitted by applicable law, the Company may delete, destroy, deidentify, anonymize, or otherwise dispose of the information using measures reasonably appropriate to the nature of the information and the systems in which it is maintained.

11.9. Residual and Backup Information. Personal Information may remain for a limited period in backups, archives, system logs, disaster recovery systems, or other residual copies after it has been deleted from active systems, where immediate removal is not reasonably practicable. Such information may remain subject to appropriate safeguards and will be deleted, overwritten, isolated, or otherwise rendered unavailable through the Company’s ordinary system and retention processes, as applicable.

Article 12. DATA SECURITY

12.1. Reasonable Safeguards. The Company will use reasonable administrative, technical, and physical safeguards appropriate to the nature of the Personal Information within its possession or control and the circumstances in which that information is Processed. These safeguards are intended to protect Personal Information against unauthorized access, acquisition, use, disclosure, alteration, loss, destruction, or other unauthorized Processing.

12.2. Access to Personal Information. The Company will seek to limit access to Personal Information to personnel, representatives, and other persons who reasonably require access for an authorized business, operational, administrative, contractual, security, claims related, or legal purpose. Access may be limited according to the nature of the information, the function being performed, and the systems through which the information is maintained.

12.3. Systems and Information Security. The Company may use security measures appropriate to its systems and operations to protect the confidentiality, integrity, and availability of Personal Information. Such measures may include access restrictions, authentication controls, system protections, record management practices, backups, or other safeguards appropriate to the nature of the information and technology involved. The particular safeguards used may change as the Company’s systems, operations, risks, and technology develop.

12.4. Third Party Service Providers. Where Personal Information is Processed on the Company’s behalf through a Third-Party Service Provider, the Company will use reasonable measures appropriate to the nature of the services and information involved in selecting and working with such providers. Third Party Service Providers may operate their own systems and security measures, and the Company does not represent that it directly controls every technical or operational safeguard maintained by an independent provider.

12.5. Security Incidents. If the Company becomes aware of unauthorized access to or acquisition, disclosure, loss, or other compromise of Personal Information within its responsibility, the Company may take reasonable steps appropriate to the circumstances to investigate the matter, contain or reduce further risk, preserve relevant information, address identified vulnerabilities where reasonably practicable, and comply with applicable notification or other legal requirements.

12.6. Customer Security Responsibilities. Customers should take reasonable steps to protect information and credentials used to access the Platform or communicate with the Company, including maintaining the confidentiality of passwords or other authentication information and using reasonable care when transmitting Personal Information. A Customer should promptly notify the Company if the Customer reasonably believes that an account, credential, communication method, or Personal Information associated with the Customer has been accessed or used without authorization.

12.7. Electronic Communications and Transmission Risks. Personal Information may be transmitted through electronic communications, networks, payment systems, electronic contracting systems, or other technologies that are not entirely within the Company’s control. Although the Company will use reasonable measures appropriate to the information and systems within its responsibility, no method of electronic transmission or storage can be guaranteed to be completely secure.

Article 13. PRIVACY RIGHTS AND CHOICES

13.1. Rights Under Applicable Law. Depending on the Customer’s place of residence, the nature of the Personal Information involved, the Company’s activities, and applicable law, a Customer may have certain rights concerning Personal Information Processed by the Company. The availability, scope, conditions, and exceptions applicable to those rights may vary. Nothing in this Policy is intended to provide a right that does not otherwise apply under applicable law or to limit a privacy right that cannot lawfully be limited.

13.2. Access to Personal Information. Where provided by applicable law, a Customer may request information concerning Personal Information that the Company maintains or Processes about the Customer and may request access to or a copy of qualifying Personal Information, subject to applicable verification requirements, limitations, and exceptions.

13.3. Correction of Personal Information. A Customer may request correction of Personal Information that the Customer reasonably believes is inaccurate or incomplete. The Company may take reasonable steps to verify the accuracy of the requested correction and may decline or limit a request where permitted by applicable law.

13.4. Deletion of Personal Information. Where provided by applicable law, a Customer may request deletion of qualifying Personal Information. A deletion request does not necessarily require the Company to delete information that it is permitted or required to retain, including information reasonably necessary to administer or document a Rental Transaction, maintain transaction or accounting records, address payments or disputes, comply with legal obligations, prevent fraud or misuse, protect Vehicles or other property, or establish, exercise, or defend legal rights.

13.5. Copies and Portability. Where applicable law provides such a right, a Customer may request a copy of qualifying Personal Information in the form required by applicable law and, where applicable, in a format that permits the Customer to transmit the information to another person or entity.

13.6. Consent-Based Processing. Where the Company relies on a Customer’s consent for a particular Processing activity and applicable law permits the consent to be withdrawn, the Customer may withdraw that consent in the manner made available by the Company. Withdrawal will apply prospectively and will not affect Processing lawfully undertaken before the withdrawal. Withdrawal of consent also does not prevent Processing that may continue on another lawful basis, or that is required or permitted by applicable law.

13.7. Opt Out Rights. Where applicable law provides a right to opt out of a particular form of Processing, the Company will provide or honor the legally required method for exercising that right. This may include rights relating to certain forms of targeted advertising, sale or sharing of Personal Information, or profiling where those activities are undertaken by the Company and the applicable law grants the Customer such a right. Nothing in this paragraph represents that the Company currently engages in each of those activities.

13.8. Verification of Requests. Before responding to a privacy request, the Company may take reasonable steps to verify the identity of the person making the request and, where applicable, the person’s authority to act on behalf of another individual. The Company may request information reasonably necessary for verification and may decline to provide Personal Information where the Company cannot reasonably verify the request or where disclosure would create an unauthorized privacy or security risk.

13.9. Authorized Representatives. Where applicable law permits a Customer to exercise privacy rights through an authorized representative, the Company may require reasonable evidence of the representative’s authority and may take additional steps permitted by applicable law to verify the Customer’s identity or confirm the authorization.

13.10. Requests Affecting Other Persons. The Company may limit, redact, or decline a request to the extent reasonably necessary to protect the Personal Information, privacy, security, confidential information, or legal rights of another person, or where another limitation or exception is permitted by applicable law.

13.11. Appeals and Additional Procedures. Where applicable law gives a Customer the right to appeal the Company’s decision concerning a privacy request, the Company will provide or make available the applicable appeal procedure and will respond in accordance with the requirements of that law.

13.12. Non-Discrimination. The Company will not unlawfully discriminate against a Customer for exercising a privacy right provided by applicable law. This provision does not prevent the Company from taking an action or maintaining a requirement that is reasonably related to a Rental Transaction, the information necessary to provide a requested service, or another distinction permitted by applicable law.

Article 14. CHILDREN’S PRIVACY

14.1. Services Not Directed to Children. The Platform, Platform Services, and the Company’s vehicle rental services are not directed to children under 13 years of age, and the Company does not knowingly seek to collect Personal Information directly from children under 13 through those services.

14.2. Rental Eligibility and Minors. The availability of a Rental Transaction is subject to the eligibility, legal capacity, driver qualification, and other requirements applicable to the particular transaction. Nothing in this Policy permits a minor or other person who does not satisfy those requirements to enter into a Rental Agreement merely because that person is able to access the Platform or provide information through it.

14.3. Information Concerning a Child Provided in Another Context. The Company may receive limited Personal Information concerning a child where that information is provided by an adult Customer or another person in connection with an accident, insurance matter, emergency, claim, communication, or other circumstance reasonably related to a Rental Transaction. Any such information will be Processed only as reasonably appropriate for the relevant purpose and in accordance with applicable law.

14.4. Information Collected Contrary to this Policy. If the Company becomes aware that it has collected Personal Information directly from a child under 13 in circumstances requiring parental consent and the required consent was not obtained, the Company will take reasonable steps to delete or otherwise address the information as required by applicable law.

14.5. Contact Concerning Children’s Information. A parent or legal guardian who reasonably believes that the Company has collected Personal Information from a child in circumstances inconsistent with this Section may contact the Company using the information provided in Section 17.

Article 15. EXTERNAL LINKS AND THIRD-PARTY SERVICES

15.1. External Services. The Platform or communications from the Company may contain links to, integrations with, or references to websites, applications, platforms, or services operated by third parties. These external services may be provided for convenience, functionality, information, or access to services relevant to a Customer or Rental Transaction.

15.2. Independent Privacy Practices. When a Customer accesses or interacts directly with an independently operated third party service, the collection, use, disclosure, retention, and protection of Personal Information by that third party may be governed by its own privacy policy, terms, notices, and legal obligations. The Customer should review the privacy information provided by the applicable third party before providing Personal Information directly to that service.

15.3. Information Provided Directly to Third Parties. Personal Information that a Customer provides directly to an independently operated third party may be Processed by that third party for its own purposes. Unless the third party is Processing the information on behalf of the Company, the Company does not determine or control the third party’s independent Processing practices.

15.4. Third Party Service Providers Distinguished. This Section does not alter the treatment of Third-Party Service Providers that Process Personal Information on behalf of the Company. The Company’s use of those providers is addressed in Section 8, and disclosures of Personal Information to third parties in connection with the Company’s activities are addressed in Section 7.

15.5. Company Responsibility. The Company does not control and is not responsible for the independent privacy practices, content, security, availability, or operation of an external third-party service merely because the Platform or a Company communication contains a link or reference to that service. This provision does not exclude or limit any responsibility that the Company has under applicable law for its own Processing of Personal Information or for the selection or use of a third party where such responsibility cannot lawfully be excluded.

Article 16. CHANGES TO THIS PRIVACY POLICY

16.1. Policy Updates. The Company may revise this Policy from time to time to reflect changes in its business operations, Platform or Platform Services, privacy practices, technology, legal or regulatory requirements, or other circumstances affecting the Processing of Personal Information.

16.2. Effective Date of Changes. When this Policy is revised, the Company will update the Effective Date shown at the beginning of the Policy. Unless applicable law requires otherwise, a revised Policy will become effective on the date stated in the revised version or on another date communicated by the Company.

16.3. Notice of Material Changes. Where the Company makes a material change to this Policy or its privacy practices, the Company may provide reasonable written or electronic notice through the Platform, by email, text message or other electronic communication, by making the revised Policy reasonably available to affected Customers, or through another method appropriate to the circumstances. The notice may identify the effective date of the revised Policy and, where appropriate, direct the Customer to review the updated Policy before continuing to use the affected Platform Service or rental related service. Where Applicable Law requires a particular form, timing, or method of notice, consent, authorization, or other affirmative action, the Company shall comply with that requirement.

16.4. Changes Requiring Consent or Authorization. An amendment to this Policy does not, by itself, constitute Customer consent or authorization for a Processing activity where applicable law requires separate consent or authorization. If a change in the Company’s Processing of Personal Information requires additional consent, authorization, or another affirmative action under applicable law, the Company will obtain or provide for that requirement before relying on the change to the extent legally required.

16.5. Prior Processing and Existing Obligations. A revision to this Policy does not alter the lawfulness of Processing undertaken before the revised Policy became effective and does not eliminate any privacy obligation or Customer right that applicable law requires the Company to preserve. Personal Information retained after a revision will be handled in accordance with the Policy then applicable to the Company’s continuing Processing of that information, subject to applicable law and any separately applicable consent or authorization.

Article 17. CONTACT INFORMATION AND PRIVACY REQUESTS

17.1. Privacy Contact. Questions concerning this Policy, the Company’s Processing of Personal Information, or an applicable privacy request may be directed to Wheelson Auto Inc., 329 Linden Ave., Woodlynne, New Jersey 08107, Email: wheelsonauto@gmail.com, Telephone: 8568391385

17.2. Submitting a Privacy Request. A Customer seeking to exercise an applicable privacy right described in Section 13 should submit the request using one of the contact methods provided in Section 17.1. The request should identify the nature of the request and provide sufficient information for the Company to understand the request and reasonably identify the Customer or relevant relationship.

17.3. Information Required to Process a Request. The Company may request additional information reasonably necessary to locate relevant records, clarify the scope of a request, protect Personal Information from unauthorized disclosure, or otherwise process the request in accordance with applicable law. Customers should not provide unnecessary sensitive information when submitting a privacy request unless specifically requested through an appropriate method.

17.4. Response to Requests. The Company will review and respond to qualifying privacy requests within the period and in the manner required by applicable law. Where permitted, the Company may request clarification, extend a response period, deny or limit a request, or provide an explanation concerning information that cannot be provided, corrected, or deleted.

17.5. Communications Concerning a Request. The Company may communicate with the person submitting a privacy request using the contact information provided with the request or information already associated with the relevant Customer relationship, where reasonably appropriate. The Company may use a different or more secure method where necessary to protect Personal Information or verify the person’s identity.

17.6. Questions and Complaints. A Customer who has a question or concern regarding the Company’s privacy practices may contact the Company using the information in Section 17.1. Where applicable law provides an additional complaint or regulatory process, nothing in this Section limits the Customer’s ability to use that process.

Source version: wheelsonauto-owner-documents-20260929
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