SlugTag Privacy Policy

This Privacy Policy explains how Panoply Apps LLC, doing business as SlugTag ("SlugTag," "we," "us," or "our"), collects, uses, discloses, retains, and protects personal information when individuals access or use the SlugTag mobile application, websites, communications, and related services (collectively, the "Services"). SlugTag is intended to facilitate voluntary commuter carpool coordination, commonly known as "slugging," primarily in Virginia, Maryland, and Washington, DC.

This Privacy Policy is a notice of our information practices. It is not a warranty that the Services will always be available, uninterrupted, error-free, secure, or suitable for any particular purpose. Service-use rules, assumptions of risk, disclaimers, and limitations of liability are addressed separately in the SlugTag Terms and Conditions. By using the Services, you acknowledge that you have received this Privacy Policy. Where consent is required by law, we will request consent separately.

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1. Scope and Role of SlugTag
This Policy applies to personal information processed by SlugTag in connection with the Services. It does not apply to information processed independently by third parties under their own privacy notices, including mobile operating-system providers, app stores, telecommunications carriers, payment processors, mapping providers, advertisers, sponsors, emergency-service providers, or websites and services linked from the Services.
For purposes of applicable privacy laws, Panoply Apps LLC generally acts as the "controller" or "business" responsible for determining why and how personal information is processed, except where another entity independently determines its own processing purposes.
The Services are intended for use in the United States and are not directed to persons outside the United States. Access from another jurisdiction does not mean that SlugTag represents that the Services or this Policy comply with that jurisdiction's laws.

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2. Information We Collect

2.1 Information You Provide
• Account and profile information, such as name, email address, mobile telephone number, password or authentication credentials, profile photo, ratings, preferences, and account settings.
• Driver and vehicle information, which may include driver's license information, vehicle make, model, color, license plate, registration-related information, insurance information, and other eligibility or verification materials. The precise information collected may change as verification methods evolve.
• Ride and commute information, including selected or ranked pickup points, origins, destinations, drop-off points, availability, ride status, favorites, referrals, and participation history.
• Communications and user content, including in-app messages, reports, reviews, feedback, survey responses, support requests, and information submitted through safety features.
• Safety and emergency information, including information you choose to provide through a panic, assistance, incident-reporting, or emergency-contact feature.
• Sponsor, advertiser, and business-account information, including contact details, campaign instructions, billing details, coupon or promotion information, and related communications.
• Subscription and transaction information. Payments may be processed by an app store or third-party payment processor. SlugTag generally receives transaction identifiers, subscription status, and limited billing-related information rather than full payment-card details.

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2.2 Information Collected Automatically
• Location information, which may include approximate or precise geolocation, pickup-zone presence, route-related information, movement signals, and location timestamps. Depending on your device permissions and feature use, location may be collected while the App is open, during an active ride or navigation session, or in the background if you separately enable background access.
• Device and technical information, such as device type, operating system and version, app version, language, time zone, IP address, mobile carrier, device or advertising identifiers, push-notification token, and diagnostic information.
• Usage and activity information, such as screens viewed, buttons selected, searches, feature engagement, referral activity, ad or coupon interactions, session timestamps, crash logs, and performance data.
• Route, map, geofence, compass, camera, and sensor information generated when you use navigation, directional guidance, safety, or location-based features.

• Cookies, software development kits (SDKs), pixels, local storage, and similar technologies used by SlugTag or service providers for authentication, security, analytics, communications, performance, attribution, and feature operation.

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2.3 Information From Other Sources
• Other SlugTag users, such as when a rider or driver submits a rating, report, referral, message, or incident description involving you.
• Verification, fraud-prevention, identity, or background-service providers, if SlugTag later uses such services.
• App stores, payment processors, analytics providers, advertising or attribution partners, and communications providers.
• Publicly available sources, government records where lawfully accessed, and public commuter or slug-line information.
• Business partners, sponsors, or organizations that lawfully provide information in connection with a campaign, benefit, referral, or account relationship.

2.4 Sensitive Information
Certain information may be considered sensitive under applicable law, including precise geolocation, driver's license information, account credentials, and information submitted through emergency or safety features. We seek to process sensitive information only when reasonably necessary for disclosed purposes and, where required, with consent. SlugTag does not sell precise geolocation information.

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3. How We Use Information
• Create, authenticate, administer, and secure accounts.
• Match and coordinate riders and drivers based on location, route, destination, preferences, availability, and other relevant factors.
• Operate messaging, favorites, ratings, referrals, Slug Points, post-ride communications, geofenced Slug Spots, navigation, directional guidance, and other current or future features.
• Verify or assess driver or account eligibility and support trust, safety, incident response, fraud prevention, and abuse detection.
• Provide, personalize, maintain, troubleshoot, test, monitor, and improve the Services.
• Send transactional communications, including authentication codes, ride updates, safety notices, account alerts, support messages, and service announcements.
• Send promotional email, SMS, push notifications, offers, or sponsor content where permitted and subject to available choices.
• Administer subscriptions, trials, rewards, promotions, sponsor placements, advertising campaigns, and coupon redemption.
• Measure performance, engagement, attribution, and campaign effectiveness, including through aggregated or deidentified reporting.
• Comply with law, legal process, contractual obligations, tax and accounting requirements, and enforce our Terms and other policies.
• Establish, exercise, or defend legal claims; investigate complaints; protect users, SlugTag, Panoply Apps LLC, and the public; and support a merger, financing, reorganization, sale, or other corporate transaction.
• Use information for another purpose disclosed when the information is collected or with consent where required.
We may modify, replace, suspend, discontinue, or introduce features over time. We may use information to operate materially similar, replacement, or successor functionality when the use is reasonably compatible with the purposes described in this Policy. If a new use is materially different or requires consent, we will provide additional notice or request consent as required by law.

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4. Location, Navigation, Camera, and Sensor Data
Location is central to ride matching, zone confirmation, navigation, directional guidance, Slug Spot alerts, safety functions, and fraud prevention. Location may be inaccurate, delayed, unavailable, or affected by device settings, signal quality, buildings, weather, network conditions, mapping data, operating-system restrictions, or third-party outages.
You may manage permissions through your device settings. Disabling or limiting permissions may prevent or degrade core features. SlugTag does not guarantee that location, mapping, routing, geofencing, camera overlays, compass directions, estimated arrivals, or safety-related transmissions will be complete, accurate, timely, or continuously available. These features are not substitutes for personal judgment, posted signs, official instructions, emergency services, or safe driving and walking practices.

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5. SMS, Push Notifications, and Other Communications
If you provide a mobile number and opt in where required, SlugTag may send SMS or other messages concerning authentication, ride coordination, active sessions, Slug Spot alerts, safety, security, subscriptions, trials, support, promotions, and service changes. Message frequency varies. Message and data rates may apply. Consent to receive marketing SMS is not a condition of purchase or use of non-marketing portions of the Services.
You may opt out of non-essential SMS by replying STOP and may request help by replying HELP, subject to carrier and provider support. You may continue to receive essential transactional or safety-related communications where permitted. Delivery is dependent on carriers, gateways, device settings, network availability, and other third parties; SlugTag does not guarantee delivery, timing, or receipt. We do not sell or disclose mobile opt-in data or phone numbers to third parties for their own unrelated marketing, except as permitted by law and described at collection.

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6. How We Disclose Information
We may disclose personal information as described below. A disclosure to a service provider acting on our behalf is not necessarily a "sale" of personal information under applicable law.
• Other users. We may share limited profile, rating, vehicle, ride, location, route, status, and messaging information with matched or otherwise authorized users as needed to facilitate the Services.
• Service providers and contractors. We may disclose information to vendors that provide hosting, database, authentication, mapping, routing, analytics, crash reporting, communications, customer support, security, fraud prevention, verification, payment, subscription, advertising-delivery, and professional services.
• Sponsors and advertisers. We may provide aggregated, deidentified, campaign-level, or coarse geographic reporting. Unless separately disclosed and permitted, SlugTag does not provide sponsors or advertisers with users' direct contact information or precise location for the sponsor's own independent marketing.
• App stores and platform providers. Apple, Google, mobile operating-system providers, and app-distribution platforms may independently collect and process information under their own terms.
• Emergency, safety, and legal recipients. We may disclose information to emergency responders, designated contacts, law enforcement, regulators, courts, or others when a user activates a safety feature; when we reasonably believe disclosure is necessary to protect life, safety, rights, or property; or when required or permitted by law.
• Corporate transactions. Information may be disclosed or transferred in connection with due diligence, financing, merger, acquisition, reorganization, bankruptcy, sale of assets, or a similar transaction, subject to applicable law and appropriate protections.
• With direction or consent. We may disclose information when you direct us to do so or consent to the disclosure.

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7. Third-Party Services, Providers, Links, and Outages
The Services depend on third-party products, networks, infrastructure, data, APIs, SDKs, and services that SlugTag does not own or control. These may include, without limitation, Supabase or successor backend and authentication providers; Stripe, Apple, Google, or successor payment and subscription providers; Mailchimp or successor email providers; Twilio, carriers, or successor SMS providers; OpenStreetMap, OpenRouteService, or successor mapping providers; app-development or hosting platforms; analytics and crash-reporting services; and app stores and mobile operating systems.
Third-party providers may collect, use, retain, secure, and disclose information under their own agreements and privacy notices. Their services, terms, technologies, security practices, availability, data quality, and functionality may change without SlugTag's control. SlugTag may add, remove, replace, or reconfigure providers as the Services evolve, provided that we will update this Policy or provide additional notice when required by law.
To the fullest extent permitted by applicable law, SlugTag is not responsible for a third party's independent acts, omissions, outages, delays, errors, data loss, security incidents, inaccurate data, service changes, policy changes, or failure to perform. However, SlugTag will use service providers and contractual protections as reasonably appropriate to the nature of the information and the Services, and will fulfill any non-waivable legal duties applicable to SlugTag.
Links or integrations do not constitute endorsement or a guarantee. You should review the privacy notices and terms of any third-party service you use.

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8. Service Changes, Interruptions, and Data Availability
SlugTag may modify, test, limit, suspend, discontinue, replace, or restore all or part of the Services, including features that collect or use information. We may do so for maintenance, security, legal compliance, vendor changes, business reasons, emergencies, capacity limitations, or other operational needs. These changes may affect the availability, accuracy, transmission, storage, synchronization, or recovery of information.
We do not promise continuous access to accounts, messages, ride history, location history, ratings, rewards, advertising records, or other data through the App. Users should not rely on the Services as the sole repository for information they must preserve. Nothing in this section limits rights that cannot lawfully be waived or SlugTag's obligations to process personal information consistently with applicable law and this Policy.

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9. Aggregated and Deidentified Information
We may create, use, and disclose aggregated, statistical, or deidentified information that is not reasonably linkable to an identified or identifiable individual. We may use such information for analytics, planning, research, product development, public reporting, sponsor reporting, and other lawful purposes. Where required by law, we will maintain deidentified information in deidentified form and will not attempt to reidentify it except to test whether deidentification methods are effective or as otherwise permitted by law.

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10. Sale, Targeted Advertising, and Profiling
SlugTag does not currently sell personal information for monetary consideration and does not sell precise geolocation information. SlugTag may display contextual or sponsor-supported content based on factors such as a selected area, route, Slug Spot, or campaign.  If SlugTag later engages in processing that triggers an opt-out right, we will provide the required notice and a method to exercise that right before or when the processing begins. SlugTag does not currently use personal information to make decisions that produce legal or similarly significant effects concerning eligibility for employment, housing, credit, insurance, education, or essential services.

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11. Data Retention and Deletion
We retain personal information for as long as reasonably necessary and proportionate to provide the Services, maintain security and integrity, support safety and dispute resolution, comply with legal and contractual obligations, enforce agreements, prevent fraud and abuse, complete transactions, maintain business records, and establish or defend legal claims. Retention periods may vary based on the category of information, account status, sensitivity, feature used, legal requirements, active complaints or investigations, and technical backup cycles.  When information is no longer reasonably needed, we may delete it, deidentify it, aggregate it, or securely isolate it until deletion is practicable. Deletion from active systems may not result in immediate deletion from backups, disaster-recovery systems, logs, or records retained for legal, security, fraud-prevention, accounting, or dispute purposes. We may retain a record of a deletion request and information necessary to prevent re-registration by a suspended or banned account, where permitted by law.

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12. Data Security and Incident Response
We use administrative, technical, and physical safeguards designed to be reasonable and appropriate to the nature of the information, the size and complexity of our operations, and reasonably foreseeable risks. Safeguards may include access controls, authentication, encryption in transit or at rest where appropriate, logging, vendor management, backups, secure development practices, and incident-response procedures. Specific controls may change as technology, risks, and the Services evolve.
No security program, transmission method, storage system, software, network, or third-party service is completely secure or error-free. Accordingly, we cannot guarantee absolute security, uninterrupted availability, or that information will never be accessed, disclosed, altered, lost, or destroyed. If a security incident occurs, we will investigate and provide notices to affected individuals, regulators, or others when required by applicable law.

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13. Your Choices and Privacy Rights
Depending on your residence, the nature of the information, and whether an applicable law covers SlugTag, you may have rights to request access, confirmation, correction, deletion, portability, or information about processing; to withdraw consent; or to opt out of certain sale, targeted advertising, or profiling activities. Rights are subject to legal exceptions and verification requirements.
• Account settings: Review or update certain profile and preference information in the App.
• Location and device permissions: Manage location, camera, sensor, contacts, notification, and similar permissions through device settings. Some choices may disable or degrade features.
• Email: Use the unsubscribe link in marketing email. Transactional and legal notices may still be sent.
• SMS: Reply STOP to opt out of non-essential texts, subject to carrier functionality.
• Push notifications: Adjust preferences in the App or device settings.
• Account deletion and privacy requests: Submit a request through Settings → Privacy & Security → Privacy Rights → Submit Privacy Request or contact info@panoplyapps.com. You do not need to create a new account solely to submit a request.
We may need to verify your identity and authority before completing a request. We may deny or limit a request where permitted by law, including when we cannot verify identity, must retain information, need to protect another person's rights, or the request is manifestly unfounded, excessive, technically infeasible, or outside the scope of applicable law. We will explain a denial where required.
Appeals: If applicable law provides an appeal right, you may appeal our decision by emailing info@panoplyapps.com with the subject line "Privacy Request Appeal" within 60 days. We will respond within the period required by applicable law and provide information about further complaint options when required.
Authorized agents may submit requests where permitted by law, subject to verification of the agent's authority and the consumer's identity. We will not unlawfully discriminate against you for exercising a privacy right.

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14. Children and Age Restrictions
The Services are intended only for individuals who are at least 18 years old. SlugTag does not knowingly collect personal information from anyone under 18. If we learn that a person under 18 has provided personal information, we may suspend the account and take reasonable steps to delete the information, subject to legal retention requirements. Parents or guardians who believe a minor has provided information should contact us promptly.

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15. Emergency and Safety Features
Any panic, assistance, emergency-contact, incident-reporting, identity-verification, rating, or safety feature is intended to support—not guarantee—safety. Information submitted through such features may be incomplete, delayed, inaccurate, unavailable, or not received because of device, network, provider, user, or system limitations. SlugTag does not operate emergency dispatch services and cannot guarantee that an alert will reach or be acted upon by emergency responders or designated contacts. In an emergency, call 911 or the appropriate local emergency number when safe and possible.

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16. Business Transfers and Changes in Ownership
If SlugTag or Panoply Apps LLC is involved in a merger, acquisition, financing, restructuring, bankruptcy, sale of assets, or transfer of all or part of the business, information may be reviewed, disclosed, or transferred as part of that transaction. A successor may continue to process information consistent with this Policy unless and until it provides notice of a materially different practice, subject to applicable law.

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17. Changes to This Privacy Policy
We may update this Privacy Policy to reflect changes in law, technology, providers, data practices, features, business operations, or the Services. The "Last Updated" date will identify the current version. We may provide notice of material changes through the App, email, SMS, a website notice, or another reasonable method. Where required by law, we will obtain consent before applying a materially different practice to information previously collected. Continued use of the Services after an updated Policy becomes effective acknowledges receipt of the updated notice, but does not by itself constitute consent where applicable law requires a separate affirmative choice.

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18. Contact Us
Panoply Apps LLC d/b/a SlugTag
Privacy Contact: Pamela Mitchell
Email: info@panoplyapps.com
Mailing Address: Panoply Apps 1320 Central Park Boulevard, Central Park Corporate Center, #200, Fredericksburg, VA 22401
In-App Request Method: Settings → Privacy & Security → Privacy Rights → Submit Privacy Request
For accessibility assistance or an alternative format of this Policy, contact us using the information above.

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