TurboPass Privacy Policy

Effective Date: September 23, 2025

Introduction

TurboPass Corporation, a Delaware Corporation (collectively “TurboPass” “we,” “us,” or “our”) operates the websites located at: https://www.turbopassreport.com/, https://www.turbopassusa.com, and https://app.turbopasspoi.com (collectively, “Site”) and related features, content, applications, or products offered by TurboPass (together with the Site, the “Services”).

TurboPass respects and protects the privacy of the users that use our Services. We maintain strict policies to ensure the privacy of those who use our Services (“End Users,” “you,” or “your”) or those who may just visit or access our Site without otherwise using our Services (collectively, “Users”). This policy (“Privacy Policy”) describes the types of information we may collect from you or that you may provide when you visit the website our Site and our practices for collecting, using, maintaining, protecting, and disclosing that information. It also describes the choices available to you, as either a trial or paying business client (“Commercial User”) or a consumer seeking to use our Site or Services because of potential transactions with our business clients (“Consumer”), regarding our use of your Personal Information and how you can access and update this information. This Privacy Policy also includes a description of certain rights that you may have over information that we may collect from you.

This Privacy Policy applies to information we collect:

• On this Site;
• In email, text, and other electronic messages between you and this Site;
• When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this policy;
• When you use our Services.

This Privacy Policy does not apply to information collected by:

• Any third party, including through any application or content that may link to or be accessible from or through the Site and / or Services.

By using the Services, you agree to this Privacy Policy. If you do not agree with our policies and practices, your choice is to not use our Services. If you have questions or concerns regarding this policy, you should first contact us at [email protected].

Summary of Data Collection, Disclosure and Sale

Here is a short summary of data and the categories of data we have collected, disclosed, and sold over the last twelve (12) months. The rest of this Privacy Policy provides more in-depth information on our privacy practices.

• Identifiers, such as contact details, such as real name, alias, address, telephone number, unique personal identifiers, online identifiers, IP address, email address, and account name.
  • Do we collect? Yes
  • Will we disclose this data as part of our business? Yes
  • Will we sell this data? No
• Categories of PI described in the California Consumer Privacy Act, GDPR or otherwise (including name, email, phone number, mailing address, birthday,)
  • Do we collect? Yes
  • Will we disclose this data as part of our business? Yes
  • Will we sell this data? No
• Commercial information: (Transaction information, purchase history, financial details, and payment information)
  • Do we collect? Yes
  • Will we disclose this data as part of our business? Yes
  • Will we sell this data? No
• Geolocation data: (device location)
  • Do we collect? Yes
  • Will we disclose this data as part of our business? Yes (only to Commercial User authorized by you as described herein)
  • Will we sell this data? No
• Internet or other electronic network activity information: (Browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems, and advertisements)
  • Do we collect? Yes
  • Will we disclose this data as part of our business? Yes
  • Will we sell this data? No
• Inferences drawn from other personal information to create a profile about a consumer: (for example, an individual’s preferences and characteristics)
  • Do we collect? Yes
  • Will we disclose this data as part of our business? Yes
  • Will we sell this data? No
• Biometric information
  • Do we collect? Yes
  • Will we disclose this data as part of our business? Yes
  • Will we sell this data? No
• Characteristics of protected classifications under California or United States federal law
  • Do we collect? Yes (optional depending on type of Service) (information in your selected government-issued ID)
  • Will we disclose this data as part of our business? Yes
  • Will we sell this data? No
• Audio, visual or similar information
  • Do we collect? Yes
  • Will we disclose this data as part of our business? Yes
  • Will we sell this data? No
• Professional or employment related information
  • Do we collect? Yes
  • Will we disclose this data as part of our business? Yes
  • Will we sell this data? No
• Non-public education information (per the Family Educational Rights and Privacy Act)
  • Do we collect? No

Information We Collect About You

We collect several types of information from you and about users of our Site depending on how you interact with us, including the following information:

• Personal Information (as defined above) which may include your:
  • Name;
  • Email address;
  • Phone number;
  • Username;
  • Social Security Number (last 4 digits) (optional depending on type of Service);
  • Optional identity or income verification information as may be requested by a Commercial User and provided by you or on your behalf as a Consumer, including but not limited to your assets, employment or payroll data, insurance, and/or utility account information; and
• Non-personal data, including any data that cannot be used on its own to identify or trace a person. We may collect your IP address, device information, or location information. When non-personal data you give to us is combined with Personal Information we collect about you, it will be treated as Personal Information and we will only use it in accordance with this Privacy Policy.
• Any other information voluntarily supplied by you to us reasonably necessary to provide the Services.

For Commercial Users Only: If you are using the Services as a User employed by a Commercial User, we may also collect the following information about you or your company:

• Biometric or other verifying information;
• Commercial User company name;
• Commercial User company address; and
• Credit or debit card number.

Children Under the Age of 16

Our Site is not intended for children under 16 years of age. No one under age 16 may provide any information on the Site. We do not knowingly collect personal information from children under 16. If you are under 16, do not use or provide any information on this Site or through any of its features, register on the Site, use any of the interactive or public comment features of this Site, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us by writing or emailing us at:

TurboPass Corporation
12274 Bandera Rd Suite 218
Helotes, TX 78023
Email: [email protected]

How We Collect Information:

We may collect and retain any information from you or your devices provided to us when you visit our Site, including:

• When you:
  • Provide it to us directly through our Site;
  • Register for an account;
  • Apply for financing with one of our lending partners;
  • Communicate with us, such as to provide feedback, request support, or ask for additional information; and
  • Subscribe to content we offer, such as newsletters, alerts, etc.
• Through automated collection methods like cookies or log files; and
• When we obtain the information from third parties, including our third-party vendors or service providers, or those third parties that you authorize to provide such information to us on your behalf. Such processing, collection, sharing or storing of data by such third parties may be processed, collected, shared or stored by TurboPass by such third parties as stated in “Who We Share Data With.”

Third-Party Use of Cookies and Other Tracking Technologies

Some content or applications, including advertisements, on the Site are served by third-parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies or other tracking technologies to collect information about you when you use our website. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control these third parties' tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

How We Use Your Information

We use information that we collect from you or that you provide to us (including, if you are a Consumer, information you authorize a third party to provide to us on your behalf) when we have a legitimate purpose for doing so, including for the following reasons:

• To verify your eligibility to use the Services;
• When it is necessary for the general functioning of the Services, including to contact you or, if you are a Commercial User, to facilitate payment and collection from your organization;
• To verify Consumer assets and deposits from Consumer’s financial institutions, or to verify a Consumer’s payroll, insurance, or utility account information, with a Commercial User for the sole purpose authorized by such Consumer;
• When it is necessary in connection with any contract you have entered into with us; (including our Terms of Service) or to take steps prior to entering into a contract with us;
• When we have a legitimate interest in using the information for the purpose of contacting you, subject to compliance with applicable law;
• When we have a legitimate interest in using the information for the purpose of detecting, and protecting against, breaches of our policies and applicable laws;
• To present our Site and its contents to Users;
• To provide you with information, products, or services that you request from us;
• To fulfill any other purpose for which you provide it;
• To notify you about changes to our Site or services we offer or provide through it;
• When we have obtained your prior consent to the use (this legal basis is only used in relation to uses that are entirely voluntary – it is not used for information processing that is necessary or obligatory in any way);
• When we have a legitimate interest in processing your information for the purpose of providing or improving our Services;
• When we have a legitimate interest in using the information for the purpose of detecting, and protecting against, actual or potential breaches of our policies or violations of applicable federal or state laws, rules, or regulations.

We may also ask for your consent to use your Personal Information for a specific purpose that we communicate to you.

For Commercial Users Only: If you are using the Services as a User employed by a Commercial User, we use information that we collect from such Commercial Users or that Commercial Users provide to us about you, including any personal information:

• To provide you with access to the TurboPass Services for which your company has subscribed;
• When it is necessary for the general functioning of the Services, including to facilitate payment and collection from, or to contact, your company;
• When it is necessary in connection with any contract your company has entered into with us.

We may use aggregated (anonymized) information about our Users, and information that does not identify any individual, without restriction.

Who We Share Data With

• Other Users. We may share your information with other Users when you use the Services (such as other Users who have invited you to use the Services or, if you are a Commercial User, who are within your same organization), as provided in this Privacy Policy. If you are a Consumer, we only share your information as authorized by you and only with the Commercial Users who have your permission to use your information because of an actual or prospective contractual relationship between you and that Commercial User.
• Affiliates and Subsidiaries. We may, for our legitimate interests, share your information with entities under common ownership or control with us who will process your information in a manner consistent with this Privacy Policy and subject to appropriate safeguards. Such parent companies, affiliates, or subsidiaries may be located in the United States.
• Successors in Interest. We may, for our legitimate interests, share your information with a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, in which personal data about our Users is among the assets transferred. You will be notified of any such change by a prominent notice displayed on our Services or by e-mail. Any successor in interest to this Privacy Policy will be bound to the Privacy Policy at the time of transfer.
• Law enforcement and other governmental agencies. We may share your information when we believe in good faith that such sharing is reasonably necessary to investigate, prevent, or take action regarding possible illegal activities or abuse of the Services or to comply with legal process or agency audits. This may involve the sharing of your information with law enforcement, government agencies, courts, and/or other organizations.
• Service Providers. We may, for our legitimate interests, share certain information with contractors, service providers, third party authenticators, and other third parties that we use to support our business (“Third-Party Service Providers”) and who are bound by contractual obligations to keep personal data confidential and use it only for the purposes for which we disclose it to them, but we are not responsible for any Third-Party Service Provider’s privacy policies or other practices.

Third Party Services and Sites

TurboPass does not control and is not responsible for the privacy policies or other practices employed by websites linked to, or from, our Site or the information or content contained therein, and we encourage you to read the privacy statements of any linked third party.

Accessing and Correcting Your Information

If you would like to prevent us from collecting your information completely, you should cease use of our Services. You can also control certain data via these other methods:

• Correction capabilities: You have the ability to access and correct any inaccuracies in your personally identifiable information by contacting us at [email protected].
• Opt-out of non-essential electronic communications: You may opt out of receiving newsletters and other non-essential messages by using the ‘unsubscribe' function included in all such messages or by contacting us directly at [email protected]. However, you will continue to receive notices and essential transactional emails.
• Optional information: You can always choose not to fill in non-mandatory fields when you submit any form or information linked to our Services.

Data Security

We implement physical, electronic and managerial control measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. We choose these safeguards based on the sensitivity of the information that we collect, process and store and the current state of technology. Our outsourced service providers who support our operations are also vetted to ensure that they too have the appropriate organizational and technical measures in place to protect your information. All information you provide to us is stored on our secure servers behind firewalls. Any Personal Information (and for Commercial Users, any payment transactions through our payment processors) will be encrypted using SSL technology.

Personal Information about our Users is stored in the United States. By providing your Personal Information, you consent to any transfer or processing in accordance with this Privacy Policy. For the avoidance of doubt, our Services are not intended for any users outside of the United States.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Site, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Site. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Site.

If you have any questions about security on our Web site, you can contact us at [email protected].

For Commercial Users only: In order to make a purchase from us, you must use our third-party payment processing vendor to finalize and pay for your order. Its privacy statement and security practices will also apply to your Personal Information. We encourage you to read that privacy statement before providing your information.

Your State Privacy Rights

State consumer privacy laws may provide their residents with additional rights regarding our use of their personal information. Under the United States California Consumer Privacy Act (CCPA), the Virginia Consumer Data Protection Act, Nevada’s, Colorado’s, Connecticut’s, Texas, Florida, Oregon Montana, and Utah’s privacy laws, and other state-specific consumer privacy laws regarding notice of information collected, residents of these states have statutory data rights.

Colorado, Connecticut, Texas, Florida, Oregon, Montana, Virginia, and Utah each provide their state residents with rights to:

• Confirm whether we process their personal information.
• Access and delete certain personal information.
• Data portability.
• Opt-out of personal data processing for targeted advertising and sales.

Colorado, Connecticut, Texas, Florida, Oregon, Montana, and Virginia also provide their state residents with rights to:

• Correct inaccuracies in their personal information, taking into account the information's nature processing purpose.
• Opt-out of profiling in furtherance of decisions that produce legal or similarly significant effects.

To exercise any of these rights please click Do Not Sell Or Share My Personal Information or email us at [email protected]. To appeal a decision regarding a consumer rights, request an appeal by emailing us at [email protected].

Your California Privacy Rights:

We describe the Personal Information we have collected from consumers in the parts of our Privacy Policy titled, “Information We Collect About You” and “How We Collect It.”

If you are a California consumer, you have the following rights. We will honor requests received to the extent required by applicable law and within the time provided by law.

• Right to access: You have the right to access (and obtain a copy of, if required) the categories of personal information that we hold about you, including the information's source, purpose and period of processing, and the persons to whom the information is shared.
• Right to rectification: You have the right to update the information we hold about you or to rectify any inaccuracies. Based on the purpose for which we use your information, you can instruct us to add supplemental information about you in our database.
• Right to erasure: You have the right to request that we delete your personal information in certain circumstances, such as when it is no longer necessary for the purpose for which it was originally collected.
• Right to restriction of processing: You may also have the right to request to restrict the use of your information in certain circumstances, such as when you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• Right to data portability: You have the right to transfer your information to a third party in a structured, commonly used and machine-readable format, in circumstances where the information is processed with your consent or by automated means.
• Right to Opt Out: You have the right to Opt Out to the use of your information in certain circumstances, such as the use of your personal information for direct marketing. To opt-out, click Do Not Sell Or Share My Personal Information.
• Right to non-discrimination: We may not discriminate against you because of your exercise of any of the foregoing rights, or any other rights under the California Consumer Privacy Act, including by:
  • denying you goods or services;
  • charging different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;
  • providing you a different level or quality of goods or services; or
  • suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services.
  • We may, however, charge different prices or rates, or provide a different level or quality of goods or services, if that difference is reasonably related to the value provided to TurboPass by your Personal Information.

We will deliver Personal Information that we are required by law to disclose to you in the manner required by law within 45 days after receipt of a verifiable request, unless we notify you that we require additional time to respond, in which case we will respond within such additional period of time required by law. We may deliver the Personal Information to you through your account, if you maintain an account with TurboPass, or, if not, electronically. If electronically, then we will deliver the information in a portable and, to the extent technically feasible, in a readily useable format that allows you to transmit the information from one entity to another without hindrance.

Requests to Exercise Your Rights:

You may request to exercise the foregoing rights by:

• Submitting a request online, or
• Emailing us at [email protected].

You may designate an authorized agent to make a request on your behalf. Please note that we may take steps to verify your identity before granting you access to information or acting on your request to exercise your rights, as required or permitted by law. We may limit our response to your exercise of the above rights as permitted by law.

Data Sharing for Direct Marketing Purposes

Residents of the State of California may request a list of all third parties to which we have disclosed certain personal information (as defined by California law) during the preceding year for those third parties’ direct marketing purposes. If you are a California resident and want such a list, please contact us via the Contact section provided below.

Privacy Disputes:

By using this Site, you agree that any dispute arising out of or relating to the Sites, the Sites’ content or the services or materials made available on the Sites, or regarding information collected or shared about you, is subject to the Choice of Law, Venue, and Class Action Waiver provisions in our Terms of Service.

Changes to the Privacy Policy

We may update this Privacy Policy to reflect changes to our privacy practices. If we make any material changes to how we treat our Users’ information, we will notify you by email (sent to the primary e-mail address specified in your account) or by means of a notice on the Site. Such changes will be effective when posted. Your continued use of our Services following the posting of any modification to this Privacy Policy shall constitute your acceptance of the amendments to this Privacy Policy. You can choose to discontinue use of the Services if you do not accept any modified version of this Privacy Policy. We encourage you to periodically review this page for the latest information on our privacy practices.