1. Introduction

This Privacy Policy is designed to inform users (both registered users and visitors) of www.haulla.com or HAULLA mobile application (each, an “Application”, and together, a “HAULLA Platform”), which offer tools enabling users to connect with waste haulers (“Haulers”) to facilitate waste collection services (the “Services”) about how Ecube Labs Co. US (“Ecube”, “us”, or “we”) gathers, uses, maintains, and discloses your personal information collected through the Services. It also explains your legal rights to control our use of that information. In this policy, “User” or “you” means any person viewing the HAULLA Platform, using the Services or submitting any personal information to Ecube in connection with using the Services.

By using the HAULLA Platform, you confirm that you have read and understand this Privacy Policy and our Terms and Terms of Service, both of which govern the use of the HAULLA Platform.

2. Information We Collect

a. Information you provide to us

i. Account Information
When you sign up for a HAULLA Account, we ask for certain personal information for the account, including information such as your name, email address, job title and employer, geographical location, and phone number.

ii. Service Registration Information
When you register for a waste collection service in HAULLA Platform, you give us the address of your dumpster and the type of waste you want to dispose.

iii. Payment Method
When you add a credit card or any other payment method to your HAULLA account, a third party that handles payments (PSP) will receive your payment information. To keep your financial data secure, we do not store full payment information on our servers.

iv. Payment Information
In order to ensure payments to Haulers, we keep information about Haulers’ bank account numbers, routing numbers, tax information, and any other payment information provided by Haulers.

b. Information we collect when you use or visit the HAULLA Platform

i. Location Information
When you open HAULLA on your mobile device, we, and third-party service providers that we engage to provide services to us, may receive your location. We may also collect the precise location of your device when the Application is running. If you label certain locations, we receive that information as well. Information about your location is necessary for us because it enables us to match you with Haulers in proximity and determine the location of your dumpster(s).

ii. Device Information
HAULLA receives information from Users’ devices, including browser type, mobile operating system, IP address, phone manufacturer, phone carrier, application installations, device identification number, push notification tokens, and geographical location data including GPS coordinates or similar information regarding the location of your mobile device.

iii. Aggregate Information
We will also create statistical, aggregated data relating to our Users and the Services for analytical purposes. Aggregated data is derived from your personal information but in its aggregated form it does not relate to or identify any individual. This data is used to understand our customer base and to develop, improve and market our services.

iv. Usage Information
To help us understand how you would use the HAULLA Platform and to help us improve it, we may collect and/or receive information about your interactions with the HAULLA Platform, such as your actions within the App, the timing of your visits, and your engagement pattern.

v. Log Data
In case of an error in the app, we collect data and information (through third party products) on your phone called Log Data. This Log Data may include information such as your device Internet Protocol (“IP”) address, device name, operating system version, the configuration of the app when utilizing the Services, the time and date of your use of the Service, and other statistics.

c. Information we collect from third parties

i. Third Party Services
If you register for an account in HAULLA Platform or otherwise link a third party service (e.g., Facebook) to your HAULLA account, we may receive information directly from those services. If you click on a third-party link, you will be directed to that site. Note that these external sites are not operated by us. Therefore, we strongly advise you to review the Privacy Policy of these websites. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.

ii. Third Party Partners
We may receive additional information about you, such as demographic data and payment information, from third party partners.

iii. We, and third party service providers that we engage to provide services to us (“Contractors”), may use web tracking technologies such as cookies, web beacons, pixel tags and clear GIFs in order to operate the Service efficiently and to collect data related to usage of the Service. Such collected data (“Web Tracking Information”) may include the address of the websites you visited before and after you visited HAULLA Platform, the type of browser you are using, your Internet Protocol (IP) address, what pages in the Services you visit and what link you clicked on, and whether you opened email communications we send to you. In order to collect Web Tracking Information and to make your use of the Services more efficient, we may store cookies on your computer. You have the option to either accept or refuse these cookies and know when a cookie is being sent to your device. If you choose to refuse our cookies, you may not be able to use some portions of the Services. We may also use web-tracking technologies that are placed in web pages on the Services or in email communications to collect information about actions that Users take when they interact with the Services or such email communications, and our Contractors may also do so. Some Web Tracking Information may include data, such as IP address data, that is unique to you. You may be able to modify your browser settings to alter which web tracking technologies are permitted when you use the Services, but this may affect the performance of the Services. The Services may use third party services, including Google Play Services, Firebase Analytics, and Fabric.

3. How we use the information we collect

a. Connect Users with Haulers;
b. Provide, improve, expand, and promote the HAULLA Platform;
c. Analyzes how users utilize the HAULLA Platform;
d. Communicate with you, either directly or indirectly;
e. Personalize your experience in HAULLA Platform;
f. Send you text messages and push notifications;
g. Facilitate transactions and payments;
h. Provide you with customer support; and
i. Find and prevent fraud.

Additionally, we use the information we collect from Haulers to:
a. Notify Haulers the status of their application by emails and text messages;
b. Examine a Hauler’s eligibility and legality to provide waste collection services; and
c. Notify Haulers about urgent collection requests.

4. How we share the information we collect

a. Sharing between Users and Haulers
Users and Haulers that have been matched can see basic information about each other, such as names, ratings, addresses, and any information that is on their profile. Although we try to facilitate a smooth communication between Users and Haulers, we do not share your actual phone number or contact information with other Users.

b. Sharing between HAULLA and third parties

i. Service Providers
We work with third party service providers to perform services on our behalf, and we may share your information with such service providers.

ii. Others

c. Legal Exception
Notwithstanding anything to the contrary in this Privacy Policy, Ecube may use any information provided by you or collected by Ecube to the extent required by law or legal process, or if in Ecube’s reasonable discretion use is necessary to investigate fraud or any threat to the safety of any individual, to protect Ecube’s legal rights or to protect the rights of third parties.

5. Your choices

a. Email Subscriptions
You can unsubscribe from our promotional emails.

b. Text Messages
You can opt out of receiving promotional text messages. You can also opt out of receiving all text messages from the HAULLA Platform.

c. Push Notifications
You can opt out of receiving push notifications in your device settings. Opting out of receiving push notifications may limit your use of the HAULLA Platform.

d. Accessing and Editing Your Information
You can access and edit some of your account information in your account settings. You can terminate your HAULLA account any time if there is nothing pending in your account. If you decide to delete your account, we may retain your account information for a certain period.

e. Location Information
You have the option to prevent your device from sharing location information at any time through your device settings but doing so may limit your use of the HAULLA Platform, including certain location-based features.

6. Other

a. Data Security
We are committed to protecting your data. Although security measures are taken, we cannot guarantee the security of your data.

b. Children’s Privacy
Children are not eligible to use or access the HAULLA Platform and their personal information is never deliberately collected by the HAULLA Platform. If we discover that a child under 13 has given us personal information, we will delete that information. If you believe that a child under 13 has given us personal information, please contact our customer support team at support@haulla.com.

c. Changes to Our Privacy Policy
We may occasionally make changes to this Privacy Policy. If there are any significant changes to the Privacy Policy, we will attempt to notify you through the HAULLA Platform, by an email, text messages, or phone. As long as you are a user of the HAULLA Platform, you are in agreement with this Privacy Policy and any changes we make to it.

e. Contact Information
You can contact our customer support team at support@haulla.com with questions or comments about this Privacy Policy.

d. Service Visitors from Outside the United States
Applications and its servers are located in the United States and are subject to the applicable state and federal laws of the United States. If you choose to access the Services, you consent to the use and disclosure of information in accordance with this Privacy Policy and subject to such laws.

7. California

California Online Privacy Protection Act Notice

On September 27, 2013, California enacted A.B. 370, amending the California Online Privacy Act to require website operators like us to disclose how we respond to “Do Not Track Signals”, and whether third parties collect personally identifiable information about users when they visit us.

a. We do not track users who do not interact with our sharing functionality across the web, and therefore do not use “do not track” signals.

b. We do not authorize the collection of personally identifiable information from our users for third party use through advertising technologies without separate member consent.

California Civil Code Section 1798.83 also permits our users who are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please send an email to support@haulla.com. Please note that we are only required to respond to one request per user each year.