Privacy Policy

This Privacy Policy is issued by Grizzly Pine Software LLC, a Wyoming Limited Liability Company ("Service Provider"). For platform account data and Solo Workspace data, Grizzly Pine Software is referred to in this policy as "we", "us", or "our" as the data controller.

Grizzly Pine Software provides the Services using intellectual property owned by Brass Buffalo Holdings LLC ("IP Holder"), including the Pinegate Logistics (formerly Fleet Logistics USA) service mark. Pinegate Logistics (formerly Fleet Logistics USA) is a service mark of Brass Buffalo Holdings LLC, used under license by Grizzly Pine Software LLC. Ownership of the software and related technology does not make Brass Buffalo Holdings your service provider or data controller.

Your privacy relationship is solely with Grizzly Pine Software, not Brass Buffalo Holdings. Brass Buffalo Holdings is not a party to this Privacy Policy.

We store gate codes: (a) provisioned by DSPs for their fleets, and (b) submitted by Solo Workspace users based on their attestation of authorized knowledge (Section 4.1 of the Terms). Gate codes are encrypted at rest and in transit, scoped to authorized workspaces, and access is logged. Property owners, managers, and HOAs may request removal of any gate code referencing their property at grizzlypinesaas@proton.me; verified requests are honored within 3 business days.

If you are a fleet operator submitting information about drivers, you represent that you have obtained necessary consents from any drivers whose information is submitted to the Services. You are responsible for complying with applicable employment law and privacy regulations regarding such data.

We collect only data necessary for delivery operations. We do not collect:

• Customer names, phone numbers, or email addresses
• Residential addresses beyond what is required for navigation and gate access within the Services
• Payment information for end customers

We do collect:

• Driver contact information for account management and approval
• Gate codes necessary for property access
• Timestamped location and access data for route verification, security monitoring, and abuse investigation
• Access logs for abuse prevention, DSP escalation, and legal compliance

Users must not submit customer-identifying information or inappropriate content through the Services. Violations may affect account approval, trigger investigation, and result in notification to your DSP.

We use session cookies and analytics tools to operate the Services securely. These may track:

• Session authentication tokens
• Device and connection signals for abuse prevention
• Usage patterns for platform improvement and security monitoring

You may disable cookies in your browser, but this may limit functionality of the Services.

When your DSP uses operations features, we may process:

• Broadcasts and acknowledgments: message content, delivery status, read receipts, and tap-to-acknowledge confirmations for wave and schedule communications
• Direct messages: one-to-one threads between drivers and dispatch or leadership, including timestamps and read status (no driver group chat)
• HR requests: sick call-outs, absence notes, and time-off requests submitted through structured forms
• Workforce documentation: reprimands, performance improvement plans, people files, and related attachments stored by DSP leadership; access is restricted by role
• Hours and scheduling: shift hours, attendance, wave confirmations, call-in status, and derived eligibility signals (for example whether a driver may be invited to call in under your DSP's rolling-hours rules)

Fleet administrators and DSP leadership may submit or maintain information about drivers and other workforce members (contact details, roster names, identifiers, HR records, and operational notes). The DSP is responsible for obtaining any consents required under employment and privacy law before submitting that information. Grizzly Pine Software processes such data on behalf of the DSP to provide the Services.

To prevent misuse, stalking, unauthorized surveillance, and theft, we monitor and log user activity within the Services. This includes access to gate codes, timestamps, and location-related signals used to detect access on non-scheduled driving days or other suspicious patterns. Flagged activity may be escalated to administrators and your DSP. Monitoring-dependent features activate only after an in-app electronic monitoring disclosure is acknowledged by the user. Monitoring reports furnished to DSPs consist of factual access logs and timestamps only; Grizzly Pine Software LLC does not generate conclusions or recommendations regarding employment decisions.

If we experience a security incident affecting personal information, we will notify affected users and DSP controllers without undue delay, and in no event later than 45 days after confirmation for users and 72 hours for DSP controllers under a Data Processing Addendum, in accordance with applicable state breach-notification law. Notifications will describe the categories of data involved and remediation steps.

Pinegate Logistics (formerly Fleet Logistics USA) is only approved for use within the United States. We do not offer, authorize, or endorse access to the Services outside U.S. territory. If you attempt to access the Services from outside the United States, your activity may be flagged, and your account may be suspended pending verification of U.S. location.

Where applicable law requires a legal basis for processing, we rely on contract performance, legitimate interests in operating and securing the Services, and compliance with legal obligations. If you are located outside the United States despite this restriction, you acknowledge that your information may be processed in the United States in accordance with U.S. law, which may not have equivalent data protection standards to your jurisdiction.

For EU or UK residents, standard contractual clauses for international transfers are available upon request at grizzlypinesaas@proton.me. We will comply with applicable laws to address foreign influence, platform abuse, data breaches, and other security threats.

We log operational activity needed to run the Services safely and fairly, including wave confirmations, broadcast delivery and acknowledgments, call-in invites, HR request submissions, and access to leadership-only workforce files. This monitoring supports abuse prevention, dispute resolution, and coordination between drivers and DSP leadership. We do not provide driver-to-driver messaging or open group chat.

Grizzly Pine Software does not sell, rent, or trade personal information to third parties. We share data only as described in this section (service providers, legal requirements, DSP escalations, and law enforcement cooperation). California residents may submit "Do Not Sell" requests, though none are applicable to our operations because we do not sell personal data.

We may share information with service providers that help us operate Pinegate Logistics (formerly Fleet Logistics USA), when required by law, or to protect the rights and safety of users and Grizzly Pine Software. We may share information with your DSP when investigating suspected misuse, and we cooperate with law enforcement when valid legal process requires disclosure of records tied to criminal activity, abuse, or security breaches.

California Residents (CCPA/CPRA): You may request disclosure of personal information collected, sources, purposes, and third parties shared with. You may request deletion of personal information. You may opt out of sale or sharing of personal information (we do not sell data). You may limit use of sensitive personal information where applicable.

Florida Residents (FDDBR): You may request access to your personal data. We will respond within 45 days. You may request correction or deletion of inaccurate data. You may opt out of profiling for automated decision-making. You may appeal a denied request within 60 days.

Virginia, Colorado, Utah, and Connecticut Residents: Similar consumer rights apply under the Virginia Consumer Data Protection Act (VCDPA), Colorado Privacy Act (CPA), Utah Consumer Privacy Act (UCPA), and Connecticut Data Privacy Act (CTDPA), including rights to access, delete, correct, and opt out of certain processing.

To exercise state-specific rights, email grizzlypinesaas@proton.me with "[State] Rights Request" in the subject line.

To process data rights requests, we may require:

• Your registered email address
• Your driver account identifier, if applicable
• Government-issued identification for high-risk requests (such as deletion or full data export)

We will respond within 45 days, or within the timeframe required by applicable state law. For urgent law enforcement or security matters, verification may occur after initial disclosure when permitted by law.