PRIVACY POLICY

State of Florida, Rev. 133C579

Version Date: May 11, 2026

We, Circuit Transit Inc., use your information to provide our transportation services to you. We will describe how we collect, store and use your information in this Privacy Policy. We take seriously our responsibilities to look after your information and we are committed to protecting your privacy. There are steps you can take to control what we do with your information and we have explained those steps in this Privacy Policy.

When we talk about your information in this Privacy Policy, we mean personal information which identify you or which could be used to identify you such as your name and contact details and your transportation arrangements. It may also include information about how you use our website and mobile application.

GENERAL

Circuit Transit Inc. and its affiliated companies (collectively, “Circuit” or “Company” or “we” or “us” or “our”) respects the privacy of its users and/or riders (“user”, “you” or “rider”) that use our website located at www.ridecircuit.com, including other media forms, media channels, mobile website or mobile application related or connected thereto (collectively, the “Website”) and we are responsible for your information. We are the controller of the information that we collect from you, and as such we control the ways your personal information is collected and the purposes for which your personal information is used.

The following Company privacy policy (“Privacy Policy”) is designed to inform you, as a user of the Website, about the types of information that Company may gather about or collect from you in connection with your use of the Website and our services. It also is intended to explain the conditions under which Company uses and discloses that information, and your rights in relation to that information. This policy specifically applies to the riders: the users who request or receive transportation. Changes to this Privacy Policy are discussed at the end of this document. Each time you use the Website, the current version of this Privacy Policy will apply. Accordingly, each time you use the Website you should check the date of this Privacy Policy (which appears at the beginning of this document) and review any changes since the last time you used the Website.

INFORMATION WE COLLECT

Personal Information You Provide. When you create an account, request service, or communicate with us, you may provide information such as your name, email address, phone number, date of birth, gender, home ZIP code, and any other information you choose to share (for example, when contacting support).

Information We Collect Automatically. When you use our apps, websites, or related services, we automatically collect certain information, including:

Device and usage information: information about your device and how you use our services, such as device type, operating system, app version, language settings, time zone, and device identifiers (for example, device ID and similar identifiers), and log information.
App interactions and events: information about your in-app activity, such as screens viewed, taps/clicks, session duration, feature usage, and actions you take within the app.
Approximate location information: derived from your IP address (primarily on the website).
Cookies and similar technologies (website): we and our service providers use cookies and similar technologies to support website functionality, analytics, and communications tools (see “Cookies and Similar Technologies” below).

Communications. If you contact us directly, we may receive additional information about you. For example, when you contact our customer support, we will receive your name, email address, phone number, the contents of a message or attachments that you may send to us, and other information.

Location Information. Circuit is all about connecting riders to our drivers. To do this, we need to know where you are. When you open Circuit on your mobile device, we receive your location. If you label certain locations, such as “home” and “work,” we receive that information, too. Your location information is necessary for things like matching riders with nearby drivers, determining drop off and pick up locations, and suggesting destinations based on previous trips. If you enable location permissions, we may collect your device’s location information to provide core app functionality (for example, matching you with pickup and drop-off locations, estimating ETAs, and improving service availability). Depending on your device settings and permissions, this may include precise geolocation while the app is in use (foreground) and, if you enable it, while the app is not actively in use (background). You can control location permissions through your device settings.

Payment. If you use payment features, payments are processed by third-party payment processors. Circuit does not store full payment card numbers or card verification values (CVV). We may receive and store transaction and payment status information (for example, payment approval/decline status, transaction amount, transaction date/time, refunds, and tokenized payment references and limited card details such as card brand and last four digits where provided by the processor).

We also collect information about how you use payment features in the app (for example, adding or updating a payment method, attempting a payment, and successful/failed payment events) to operate the service, prevent fraud, troubleshoot issues, and improve reliability.

Device Information. Circuit receives information from users’ devices, including IP address, web browser type, mobile operating system version, phone carrier and manufacturer, application installations, device identifiers, preferences and settings, and push notification tokens. We do not use mobile advertising identifiers (such as IDFA/AAID) for app tracking or advertising purposes.

In-Vehicle Recordings. Circuit vehicles may be equipped with devices that use video camera and/or sensor technology to record events inside and outside the vehicle. If such devices are installed in our vehicles, we may collect video images of drivers and passengers, along with telematics data that includes vehicle location, speed, braking, relative proximity to other vehicles, and collision events that may occur during your ride. Subject to notice or consent requirements in accordance with applicable law, Circuit may also collect audio recordings within the vehicle. Certain devices may employ artificial intelligence to process images of a driver in real-time in order to identify or alert the driver to safety-related events such as indicators of distracted driving or unsafe distances between moving vehicles. To the extent that such images would be considered biometric information under applicable laws, the devices do not store or transfer such information and we do not disclose biometric information to third parties for any commercial purposes. In cases where we collect data from in-vehicle recording devices, Circuit will provide notice to passengers that there is a recording device in the vehicle; such notice may be provided through physical signs on the exterior and/or interior of the vehicle.

Usage Information (Apps and Website). To help us understand how you use our services and to help us improve them, we automatically receive information about your interactions with the apps and website, which may include ride-related information (such as the date, time, pickup/drop-off locations, destination, distance, route, and fare/payment status), as well as app and website interactions (such as the screens or pages you view, features you use, actions you take, and the dates and times of your visits).

App Analytics and Event Tracking. We collect and analyze event data generated when you use our apps to help operate, maintain, and improve the user experience. Event data may include:

General app & session events (for example, app open/close, session start/end, performance and crash indicators);
Signup and account events (for example, account creation and verification steps);
Search and booking flow events (for example, searching service areas, selecting pickup/drop-off points, request/booking attempts, and cancellations);
Ride-related events (for example, ride requests, matching, pickup, drop-off, and service outcomes);
Payment and financial feature events (for example, payment attempts and outcomes, refunds, and other payment feature interactions).

How event data is linked. Event data may be associated with your account and/or device identifiers.

Why we collect it. We use event data to:

provide and operate the services (including routing and dispatch-related features);
monitor performance and diagnose technical issues;
prevent fraud and abuse;
understand how features are used and improve product design and reliability; and
support customer service and resolve disputes.

Data minimization. We design our event tracking to collect information that is reasonably necessary for the purposes described above.

User Feedback. At Circuit, we want to make sure users are always enjoying great rides. Riders and drivers may rate and review each other at the end of every ride. We receive information about these ratings and reviews. We may also ask for participation in polls, contests, surveys or other features of our service, or response to offers or advertisements.

HOW WE USE THE INFORMATION WE COLLECT

We can only use your information for one or more of these reasons:

To fulfill a contract we have with you;

If we have a legal duty to use your information for a particular reason;

When you consent to it;

When it is in our legitimate interests. Legitimate interests are our business or commercial reasons

for using your information;

In conformance with the requirements of a local, state or federal law enforcement agency.

Within those stated reasons, we use the information we collect from all users to:

Deliver the services that you have requested;

Connect riders with drivers;

Provide, improve, expand, and promote the services;

Analyze how the users use the Website including measuring user interest;

Evaluate information on your Website visit and how you move around different sections of our

Website for analytics purposes to understand how people use our Website so that we can make it more intuitive”

Company communications with you, either directly or through one of our partners, by email,

telephone and/or mobile devices;

Understand usage of our apps and website (including feature performance and reliability) and improve our services;

Operate, maintain, and secure our services, including fraud prevention, safety, and troubleshooting;

Manage communications (including responding to inquiries and sending service-related messages, and, where permitted by law, marketing communications);

Customize the Circuit experience for you;

Enhance safety and security with the use of in-vehicle recordings;

Assist insurance investigation and/or law enforcement; and

Provide you with customer support including resolving disputes and troubleshooting problems.

Company communications will use your name, telephone and/or email address to send you notifications regarding new services offered by the Website that we think you may find valuable. We may also send you service-related announcements from time to time through the general operation of the service. Generally, you may opt out of such company communications by unsubscribing to email communications or by contacting us, though we reserve the right to send you notices about your account, such as service announcements and administrative messages, even if you opt out of all voluntary email notifications.

Marketing communications. We may send service-related messages (for example, receipts, ride updates, and administrative messages) and, where permitted by law, marketing communications. You can opt out of marketing communications by following the unsubscribe instructions in those messages or contacting us.

GATHERING THE INFORMATION

Web Cookies

A “Web Cookie” is a string of information which assigns you a unique identification that a website stores on a user’s computer, and that the user’s browser provides to the website each time the user submits a query to the website. We use cookies on the Website to keep track of services you have used, to record registration information regarding your login name and password, to record your user preferences, to keep you logged into the Website and to facilitate purchase procedures. We also use Web Cookies to track the pages that users visit during each Website session, both to help us improve users’ experiences and to help us understand how the Website is being used. We may use both session cookies and persistent cookies. A session cookie disappears after you close your browser. A persistent cookie remains after you close your browser and may be accessed every time you use the Website. We analyze and disclose in aggregated form information gathered using Web Cookies, so as to help us, our partners and others better understand how the Website is being used. WEBSITE USERS WHO DO NOT WISH TO HAVE WEB COOKIES PLACED ON THEIR COMPUTERS SHOULD SET THEIR BROWSERS TO REFUSE WEB COOKIES BEFORE ACCESSING THE WEBSITE, WITH THE UNDERSTANDING THAT CERTAIN FEATURES OF THE WEBSITE MAY NOT FUNCTION PROPERLY WITHOUT THE AID OF WEB COOKIES.

Web Beacons

A “Web Beacon” is an object that is embedded in a web page or email that is usually invisible to the user and allows website operators to check whether a user has viewed a particular web page or an email. We may use Web Beacons on the Website and in emails to count users who have visited particular pages, viewed emails and to deliver co-branded services. Web Beacons are a technique we may use to compile aggregated statistics about Website usage. Web Beacons collect only a limited set of information, including a Web Cookie number, time and date of a page or email view and a description of the page or email on which the Web Beacon resides. You may not decline Web Beacons. However, they can be rendered ineffective by declining all Web Cookies or modifying your browser setting to notify you each time a Web Cookie is tendered, permitting you to accept or decline Web Cookies on an individual basis.

Analytics (Apps and Website)

We may use analytics tools to understand how our apps and website are used, to monitor performance, and to improve functionality. Current analytics providers may include Mixpanel and Google Analytics. These tools may collect information such as device information, usage information, and interactions with our services. We also use website tools such as HubSpot to help manage website forms, communications, and related website analytics and functionality.

Your choices. You can control cookies through your browser settings. If you do not want Google Analytics to be used on the website, you can install the Google Analytics opt-out browser add-on (available from Google).

Note: We do not use mobile advertising identifiers (such as IDFA/AAID) for app tracking or advertising purposes.

Cross-border processing. Circuit is based in the United States and we may store or process information in the United States and other locations where we or our service providers operate. These locations may have different data protection laws than your place of residence. We take steps designed to ensure an appropriate level of protection when personal information is processed by our service providers.

Additional information for Canada (including Québec). If you are located in Canada, including Québec:

Service providers and cross-border transfers. We may transfer personal information to service providers located outside your province (including outside Québec and Canada) to help us provide the services (for example, cloud hosting, customer support tools, and payment processing).
Privacy Officer. The person responsible for personal information protection at Circuit can be contacted at: Compliance Manager, legal@ridecircuit.com, Circuit Transit Inc., 501 East Las Olas Suite 300, Fort Lauderdale, FL 33301.
Questions and complaints. You may contact us using the information above to ask questions about our privacy practices or to submit a complaint.

SHARING THE INFORMATION WITH THIRD PARTIES

API and Integration Partners. If you connect to the Website through an integration with a third-party service, we may share information about your use of the Website with that third party. We may share your information with our third-party partners in order to receive additional information about you. We may share your name and contact information and transaction-related information with our authorized service providers who process payments. Payment processors may receive payment information needed to process your transactions; Circuit generally receives only limited payment details and transaction status information (as described above).

Third Party Services. We may share your information, which may include your name and contact information (including email address) with our authorized service providers that perform certain services on our behalf. These services may include fulfilling orders, providing customer service and marketing assistance, performing business and sales analysis, supporting the Website’s functionality and supporting contests, sweepstakes, surveys and other features offered through the Website. We may also share your name, contact information and credit card information with our authorized service providers who process credit card payments. These service providers may have access to personal information needed to perform their functions but are not permitted to share or use such information for any other purpose.

Service Providers. The Website may allow you to connect with other websites, products, or services that we do not have control over. We cannot speak to the privacy practices of these third parties. Circuit’s Privacy Policy does not apply to information provided to or gathered by the third parties that operate them. Before visiting a third party, or using a third-party application, whether by means of a link on the Website, directly through the Website or otherwise, and before providing any information to any such third party, we encourage users to read these third-party privacy policies before deciding whether to use their services.

Social Media. We may use hyperlinks on the Website which will redirect you to a social network if you click on the respective link. However, when you click on a social plug-in, such as Facebook’s “Like” button, Twitter’s “tweet” button or the Google+, that particular social network’s plugin will be activated and your browser will directly connect to that provider’s servers. Settings regarding privacy protection can be found on the websites of these social networks and are not within our control.

Do-Not-Track-Policy. Most web browsers and some mobile operating systems include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have information about your online browsing activities monitored and collected. Because there is not yet a common understanding of how to interpret the DNT signal, the Website currently does not respond to DNT browser signals or mechanisms.

In addition, we may share your information with third parties in the following cases:

While negotiating or in relation to a change of corporate control such as a restructuring, merger,

sale of our assets, bankruptcy or other sale of all or a portion of our assets;

If a government authority requests information and we think disclosure is required or appropriate

in order to comply with laws, regulations, or a legal process;

With law enforcement officials, government authorities, or third parties with efforts to investigate,

prevent or take other action regarding illegal activity, suspected fraud or other wrongdoing if we

think doing so is necessary to protect the rights, property, or safety of the Circuit community,

Circuit, or the public;

To comply with a legal requirement or process, including but not limited to, civil and criminal

subpoenas, court orders or other compulsory disclosures.

With our insurance partners to help determine and provide relevant coverage in the event of an

incident;

To provide information about the use of the Website to potential business partners in aggregated

or de-identified form that cannot reasonably be used to identify you; and

Whenever you consent to the sharing.

HOW LONG WE KEEP YOUR INFORMATION

We retain personal information for as long as reasonably necessary to provide the services, fulfill the purposes described in this policy, comply with legal obligations, resolve disputes, enforce agreements, and protect our legal rights.

Retention periods vary depending on the type of information and how it is used. For example, we may retain certain transactional records for accounting and legal compliance, and retain app event logs for troubleshooting, security, and product improvement for a limited period consistent with our internal retention schedule.

SECURITY OF YOUR INFORMATION

We take the security of your information seriously and use technical measures such as encryption and password protection to protect your information from loss, theft, alteration, misuse or destruction. We also use administrative, technical, and physical safeguards to protect your personal information, for example by limiting the number of people who have access to the databases in which the information is held. We keep these security safeguards under review and refer to industry security standards to keep up to date with current best practice. However, no method of transmission or storage is completely secure, and we cannot guarantee absolute security. We cannot guarantee that only authorized persons will view your information. We are not responsible for third-party circumvention of any privacy settings or security measures.

Breach notification. If we become aware of a security incident involving personal information, we will evaluate the incident and notify individuals and regulators as required by applicable law and as appropriate based on the nature of the incident.

We are dedicated to protect all information on the Website as is necessary. However, you are responsible for maintaining the confidentiality of your information by keeping your password confidential. You should change your password immediately if you believe someone has gained unauthorized access to it or your account. If you lose control of your account, you should notify us immediately.

YOUR RIGHTS

You are entitled to see copies of all personal information held by us. You may at any time review or change your information by logging into your account settings and profile or contacting us using the contact information below. Upon your request, we will deactivate or delete your account and contact information from our active databases. Such information will be deactivated or deleted as soon as practicable based on your account activity and accordance with our deactivation policy and applicable law. We will retain in our files some information to prevent fraud, to troubleshoot problems, to assist with any investigations, to enforce our Terms of Use and to comply with legal requirements as is permitted by law. Therefore, you should not expect that all your information will be completely removed from our databases in response to your requests. Additionally, we keep a history of changed information to investigate suspected fraud with your account.

If you gave us your consent to use your information, e.g. so that we can send you marketing emails, you can withdraw your consent. You can withdraw your consent through your account settings, unsubscribing from our commercial or promotional communications or contacting us using the contact information below. Please note that even if you withdraw your consent, we can still rely on the consent you gave as the lawful basis for processing your information before you withdrew your consent.

While you can prevent your device from sharing location information at any time through your mobile device’s operating system settings, user and driver location is core to the Website and without it we cannot provide our services to you.

You can object to our use of your information where we rely on our legitimate interests to do so.

To raise any objections or to exercise any of your rights, you can contact us using the contact information below.

When you get in touch, we will come back to you as soon as possible and where possible within one month. Please note that if your request is more complicated, it may take a little longer to come back to you and the response deadline can be extended by two months of your request where necessary. There is no charge for most requests, but if you ask us to provide a significant amount of information for example, we may ask you to pay a reasonable administration fee. We will also ask you to verify your identity before we provide any information to you.

If Company decides to change this privacy policy, the changes will be posted on this page.

Company may, in its sole discretion, change this Privacy Policy from time to time. Any and all changes to Company’s Privacy Policy will be reflected on this page and the date new versions are posted will be stated at the top of this Privacy Policy. Unless stated otherwise, our current Privacy Policy applies to all information that we have about you and your account. Users should regularly check this page for any changes to this Privacy Policy. Company will always post new versions of the Privacy Policy on the Website. However, Company may, as determined in its discretion, decide to notify users of changes made to this Privacy Policy via email or otherwise. Accordingly, it is important that users always maintain and update their contact information.

CHILDREN

The Children's Online Privacy Protection Act ("COPPA") protects the online privacy of children under 13 years of age. Our services are not directed to children and we do not knowingly collect or maintain information from anyone under the age of 16, unless or except as permitted by law. Any person who provides information through the Website represents to us that they are 16 years of age or older (and, if 16 or 17 years of age, that they have permission from a parent or legal guardian where required by applicable law). We do not knowingly collect personal information from individuals under 16 in connection with account registration. If we learn that a person under 16 has created an account, we will take appropriate steps to delete or de-identify information and deactivate the account, as permitted by law.

CALIFORNIA PRIVACY RIGHTS

California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about the information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year. If applicable, this information would include a list of the categories of the information that was shared and the names and addresses of all third parties with which we shared information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to our privacy officer as listed below. If you are a California resident, you have the right to request that we delete the information we have collected from you, with a number of exceptions including but not limited to, when the information is necessary for us to complete the transaction, provide you a service, protect your security and prosecute those responsible for breaching it, fix our system in the case of a bug, comply with a legal obligation or make other lawful uses of the information.

If you have any questions regarding our Privacy Policy, please contact our offices at:

Circuit Transit Inc.

501 East Las Olas

Suite 300

Fort Lauderdale, FL 33301

Phone: 646-504-3733