This Privacy Policy was last updated on [22/06/2021].

1. INTRODUCTION

1.1 We are SoonAs Solutions Limited ("we"/"us"/"our"). 1.2 This Privacy Policy (together with any other policies or documents referred to in it) applies to verified drivers only and describes the type of information that we collect from you ("you/your") through our consideration of, and discussions with you concerning, your application to be a verified driver on the App (which we refer to as the "On-Boarding Process") and through your use of our delivery and collection mobile app known as "SoonAs Driver" ("App") and our website ([www.sooonas.com]) ("Website"), how that information may be used or disclosed by us and the safeguards we use to protect it. 1.4 We have drafted this Privacy Policy to be as clear and concise as possible. Please read it carefully to understand how we will collect and use your data. 1.5 This Privacy Policy may change from time to time and your continued use of the App and/or the Website is deemed to be acceptance of such changes, so please check periodically for updates. 1.7 If you have any comments on this Privacy Policy, please email them to [PRIVACY@SOONAS.COM]. 1.8 You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact our Data Protection Officer in the first instance.

2. WHO WE ARE

2.1SoonAs Solutions Limited is the data controller for the purposes of the Data Protection Legislation (as defined in paragraph 2.2 below) and shall be responsible for your personal data. 2.2 Further details about us: • Our registered company number is 13149258. • Our registered address is International Logistics Centre, Bonehill Road, Tamworth, Staffordshire, B78 3HH. • Our representative Privacy Manager (who is responsible for overseeing questions in relation to this privacy policy) can be contacted at [PRIVACY@SOONAS.COM]. 2.3 We respect your right to privacy and will only process personal information about you in accordance with the "Data Protection Legislation" which for the purposes of this Privacy Policy shall mean: (i) unless and until the GDPR is no longer directly applicable in the UK, the retained General Data Protection Regulation ((EU) 2016/679) ("UK GDPR"), as amended or updated from time to time and then (ii) any successor legislation to the UK GDPR or the Data Protection Act 2018 and other applicable privacy laws.

3. WHAT WE MAY COLLECT

3.1"Personal data", or "personal information", means any information about an individual from which that person can be identified. It does not include data which does not relate to an identified or identifiable natural person or to personal data rendered anonymous in such a manner that the data subject is no longer identifiable. 3.2 We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows: • Identity Data includes first name, last name, username, email address and phone number, a photograph of you and a copy of your driver’s licence or passport. • Vehicle Data includes vehicle registration plate and insurance policy details (which may contain Identity Data). • Contact Data includes billing address, invoicing address, email address and telephone numbers. • Financial Data includes bank account details. • Transaction Data includes details about payments processed via the App. • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access the Website and/or the App. • Profile Data includes your username and password. • Usage Data includes information about how you use our App and Website. • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences. • Interaction Data includes any information that you might provide to any discussion forums on the Website and/or the App. • Cookies. Like many websites, we use "cookies" to enhance your experience and gather information about visitors and visits to our websites. Please refer to the "Cookies" section at paragraph 7 below for further information. • Third Parties and Information we receive from other sources. We may receive information about you if you use any of the other websites we operate or through the services we provide. In this case we will have informed you when we collected that data that it may be shared internally and combined with data collected via the App or on our Website. We may also receive data from third parties (including, for example, business partners, suppliers, sub-contractors, advertising networks, analytics providers (such as Google Analytics), and search information providers. • Analytics includes third-party analytics services (such as Google Analytics) to evaluate your use of the Website and/or the App (if applicable), compile reports on activity, collect demographic data, analyse performance metrics, and collect and evaluate other information relating to our Website, the App and internet usage. These third parties use cookies and other technologies to help analyse and provide us with the data. By accessing and using the Website and/or the App, you consent to the processing of data about you by these analytics providers in the manner and for the purposes set out in this Privacy Policy. 3.3 We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy. 3.4 We do not collect any Special Categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences. 3.5 In some instances, it may be appropriate for us to combine your information with other information that we may be holding about you, such as combining your name with your geographic location or your browsing or purchasing history. 3.6 The Website and the App are not intended for children and we do not knowingly collect data relating to children. 3.7 It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

4. OUR LEGAL BASIS FOR PROCESSING YOUR PERSONAL INFORMATION

4.1 In accordance with our obligations under UK GDPR we will ensure that your personal data is processed lawfully, fairly, and transparently, without adversely affecting your rights. 4.2 We will only process your personal data if at least one of the following basis applies: (a) you have given consent to the processing of your personal data for one or more specific purposes; (b) the processing is necessary for the performance of a contract to which you are a party or in order to take steps at the request of you prior to entering into a contract; (c) the processing is necessary for compliance with a legal obligation to which we are subject; (d) the processing is necessary to protect the vital interests of you or of another natural person; (e) the processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller; and/or (f) the processing is necessary for the purposes of the legitimate interests pursued by us or by a third party such as our financial payments, except where such interests are overridden by the fundamental rights and freedoms of the data subject, in particular where the data subject is a child.

5. HOW WE MAY COLLECT AND USE YOUR PERSONAL DATA

5.1 We (or third party data processors, agents and sub-contractors acting on our behalf) may collect, store and use your personal information by way of different methods to collect data from and about you including through: (a) Direct interactions. You may give us your information during the On-Boarding Process, your use of the App and the Website and your general relationship with us. This includes personal data you provide when you: (i) submit an application to us to be a verified driver; (ii) disclose information to us as part of the On-Boarding Process; (iii) use the App and Website; (iv) create an account on the App and the Website; (v) request jobs or marketing to be sent to you; and/or (vi) give us some feedback. 5.2 We may use this personal information in the following ways: (a) to make a decision about your application to be a verified driver on the website and/or App; (b) ascertaining fitness to work; (c) to monitor your use of our information and communication systems to ensure compliance with our policies; (d) to conduct data analytics studies to review and better understand how the website and/or App are being used; (e) to prevent fraud; and (f) making arrangements for the termination of your access to the website and/or App.

6. MARKETING

6.1We would like to send you information about our products and services which may be of interest to you. Where we have your consent or it is in our legitimate interests to do so, we may do this by post, email, telephone, text message (SMS), automated call or mobile push notifications. 6.2 We will only ask whether you would like us to send you marketing messages when you tick the relevant boxes when you register for the first time, or tick the relevant box within your profile settings. 6.3 If you have previously agreed to being contacted in this way, you can unsubscribe at any time by: (a) contacting us at privacy@soonas.com; (b) using the ‘unsubscribe’ link in emails or ‘unsubscribe’ in the mobile text; (c) updating your marketing preferences on our www.soonas.com/profile. 6.4 For more information on your rights in relation to marketing, see ‘Your rights’ below.

7. COOKIES

7.1We use cookies to distinguish users and improve our Website. 7.2 You can set your browser to refuse all or some cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. 7.3 Please look at our Cookie Policy [www.soonas.com/cookies] for more information about the cookies we use.

8. TRANSFER OF YOUR INFORMATION OUT OF THE UK AND EEA

8.1We may transfer your collected data to storage outside the United Kingdom (UK). If we do store or transfer data outside the UK, we will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK and under the UK GDPR. 8.2 Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented: (a) we will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data; or (b) where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK. 8.3 Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

9. KEEPING YOUR PERSONAL INFORMATION SECURE

9.1 Data security is of great importance to us, and to protect your data we have put in place suitable physical, electronic and managerial procedures to safeguard and secure data collected through our Website. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. 9.2 We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so. 9.3 We have implemented security measures such as a firewall to protect any data and maintain a high level of security. 9.4 Notwithstanding the security measures that we take, it is important to remember that the transmission of data via the internet may not be completely secure and that you are advised to take suitable precautions when transmitting to us data via the internet and you take the risk that any sending of that data turns out to be not secure despite our efforts. 9.5 If we give you a password upon registration on our App or Website, you must keep it confidential. Please don’t share it. 9.6 We will keep personal data for as long as is necessary to fulfil the purposes we collected it for. We may however be required to retain personal data for a longer period of time to ensure we comply with our legislative and regulatory requirements. We review our data retention obligations to ensure we are not retaining data for longer than we are legally obliged to and to determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means.

10. DISCLOSING YOUR PERSONAL INFORMATION

10.1 We may share your personal information with the following cases: (a) other businesses in our group for the purposes set out above; (b) third parties to protect against fraud or credit risks; (c) other third parties if we have a legal obligation to do so, or in order to protect other people’s property, safety or rights. 10.2 We may also disclose your personal information to third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy. 10.3 We may contract with third parties to help us run our business. These may include payment processing, search engine facilities, advertising and marketing. In some cases, the third parties may require access to some or all of your data. The third parties we share you personal information with, and details of their privacy policies, are as follows: (a) The Rocket Science Group LLC (t/a Mailchimp) (https://mailchimp.com/legal/privacy/); 10.4 Where any of your data is required for such a purpose, we will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, our obligations, and the obligations of the third party under Data Protection Legislation and the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

11. YOUR RIGHTS

11.1 When you submit information via our Website, you may be given options to restrict our use of your data. We aim to give you strong controls on our use of your data (including the ability to opt-out of receiving emails from us which you may do by unsubscribing using the links provided above in this Privacy Policy). 11.2 Under Data Protection Legislation, you have the right to: (a) request access to, deletion of or correction of, your personal data held by us at no cost to you; (b) request that your personal data be transferred to another person (data portability); (c) be informed of what data processing is taking place; (d) restrict processing; (e) to object to processing of your personal data; and (f) complain to a supervisory authority. 11.3 You also have rights with respect to automated decision-making and profiling as set out in section 12 below. 11.4 You have the right to ask us not to process your personal data for direct marketing purposes. We will usually inform you (before collecting your personal data) if we intend to use your personal data for such purposes or if we intend to disclose your information to any third party for such purposes. 11.5 If you would like to exercise any of your legal rights, please: (a) contact us at PRIVACY@SOONAS.COM; (b) let us have enough information to identify you [eg ACCOUNT NUMBER, USERNAME, REGISTRATION DETAILS]; (c) let us have proof of your identity and address (e.g. a copy of your driving licence or passport and a recent utility or credit card bill); and (d) let us know the information to which your request relates.

12. AUTOMATED DECISION-MAKING AND PROFILING

12.1 In the event that we use personal data for the purposes of automated decision-making and those decisions have a legal (or similarly significant effect) on you, you have the right to challenge such decisions under Data Protection Legislation, requesting human intervention, expressing their own point of view, and obtaining an explanation of the decision from us. 12.2 The right not to be subject to decisions based solely on automated data processing if the decisions produce legal (or similarly significant) effects does not apply in the following circumstances: (a) the decision is necessary for the entry into, or performance of, a contract between you and us and appropriate measures are in place to safeguard your rights; (b) the decision is authorised by law; or (c) you have given you explicit consent. 12.3 Where we use your personal data for profiling purposes, the following shall apply: (a) Clear information explaining the profiling will be provided, including its significance and the likely consequences; (b) Appropriate mathematical or statistical procedures will be used; (c) Technical and organisational measures necessary to minimise the risk of errors and to enable such errors to be easily corrected shall be implemented; and (d) All personal data processed for profiling purposes shall be secured in order to prevent discriminatory effects arising out of profiling.