Privacy Policy

Effective Date: May 12, 2026

Last Updated: May 12, 2026

Version: 2.0

1. Introduction

PPI Measure ("we," "us," or "our") respects your privacy and is committed to protecting your personal information. This Privacy Policy describes how we collect, use, disclose, and safeguard your information when you use our PPI Measure mobile application and related services (collectively, the "Services").

This Privacy Policy applies to users worldwide and is designed to comply with applicable privacy laws, including:

• United States: State privacy laws including the California Consumer Privacy Act (CCPA/CPRA), the Washington My Health My Data Act, the Oregon Consumer Privacy Act (OCPA), and other applicable state laws

• Canada: Personal Information Protection and Electronic Documents Act (PIPEDA) and provincial privacy laws

• Indonesia: Law No. 27 of 2022 on Personal Data Protection (PDP Law)

• Malaysia: Personal Data Protection Act 2010 (PDPA)

• European Union: General Data Protection Regulation (GDPR) for any EU users

2. Information We Collect

2.1 Personal Information You Provide

• Account Information: Name, email address, company name, job title, phone number

• Profile Information: Professional details, industry sector, location

• Communication Data: Messages, feedback, customer support inquiries

• Payment Information: Billing details, subscription information (processed by third-party payment processors)

2.2 Material Inspection Data

• Measurement Data: Estimated NFC (Non-Fibrous Content), moisture content, outthrows, and material grades generated by the AI

• Material Information: Details about recycled cardboard, paper, plastic (LDPE), pallets, and other materials being measured or inspected

• Inspection Photographs: Photos of bales, materials, and inspection scenes captured through the App

2.3 Safety & Claims Data

• Safety Documentation: Photographs of loading patterns, trailers, containers, equipment, and load conditions

• Loader and Operator Information: Names, identification numbers, signatures, and self-attestations of personnel involved in loading

• Claim Records: Photographs, descriptions, dates, locations, counterparty information, financial impact estimates, supporting documentation, and communication relating to submitted claims (including claims for damaged trailers/containers, non-OCC contamination, unsafe loading, and other incidents)

• Witness Information: Names and statements of witnesses identified in safety or claim reports

2.4 Load Documentation Data

• Load Photographs: Photos of loads, bales, scale tickets, Bills of Lading, and related paperwork

• Driver Information: Driver names, identification numbers, and trailer/container assignments

• Load Identifiers: Release numbers, BOL numbers, trailer/container numbers, customer information, BOL details, and scale ticket data

2.5 Logistics and Location Data

• Location Data: GPS coordinates, city/region data, and facility identifiers used for load tracking, logistics visualization, and operational reporting

• Asset Tracking Data: Status, position, and movement information for trucks, trailers, containers, and vessels

• Performance Data: Time stamps, load duration, dwell time, target metrics, and performance indicators

• Third-Party Logistics Data: Information received from carriers, vessel-tracking services, or other logistics partners that may be associated with your loads

2.6 Device and Technical Information

• Device Information: Device type, operating system, unique device identifiers

• Sensor Data: Camera, accelerometer, and other sensor data used for measurements and photo capture

• Network Information: IP address, connection type, network performance data

2.7 Automatically Collected Information

• Log Data: Access times, pages viewed, actions taken within the Services

• Cookies and Tracking Technologies: See Section 9 for details

• Third-Party Data: Information from integrated services and business partners

3. How We Use Your Information

3.1 Primary Purposes

• Service Delivery: Provide measurement analysis, safety documentation, claims processing, load documentation, and logistics tracking

• Account Management: Create and maintain your account, process subscriptions

• AI Improvement: Train and enhance our artificial intelligence algorithms for material inspection, pattern recognition, and quality analysis

• Claims Facilitation: Route claims data to the relevant counterparties identified by you (e.g., suppliers, carriers, customers, or insurers)

• Customer Support: Respond to inquiries and provide technical assistance

• Quality Assurance: Monitor and improve Service performance and accuracy

3.2 Secondary Purposes

• Research and Development: Develop new features and improve existing Services

• Industry Analytics: Create aggregated, anonymized insights about recycling industry trends, logistics performance, and safety patterns

• Marketing Communications: Send relevant updates about Services and industry news (with consent)

• Legal Compliance: Meet regulatory requirements and protect legal rights

• Security: Detect fraud, prevent abuse, and ensure platform security

3.3 Legal Bases for Processing (GDPR)

Where applicable, we process personal information based on:

• Contract Performance: To provide Services you've requested

• Legitimate Interests: For business operations, security, and service improvement

• Consent: For marketing communications and optional features

• Legal Obligation: To comply with applicable laws and regulations

4. Information Sharing and Disclosure

4.1 We May Share Information With:

• Service Providers: Third-party vendors who assist with hosting, analytics, payment processing, and customer support

• Business Partners: Companies that integrate with our Services (with your consent)

• Claim Counterparties: When you submit a claim through the Services, claim records and supporting evidence may be shared with the suppliers, carriers, customers, brokers, insurers, or other parties involved in resolving the claim

• Logistics Partners: Carriers, vessel-tracking services, and other logistics partners as needed to provide tracking and reporting functionality

• Affiliates: Our corporate family members for internal business purposes

• Professional Advisors: Lawyers, auditors, and consultants bound by confidentiality obligations

4.2 We May Disclose Information When:

• Legal Requirements: Required by law, court order, or government request

• Safety Protection: To protect rights, property, or safety of users or others

• Business Transfers: In connection with mergers, acquisitions, or asset sales

• Consent: When you explicitly authorize disclosure

4.3 We Do NOT:

• Sell personal information to third parties

• Share measurement, safety, or claims data with competitors

• Use your data for advertising targeting by third parties

• Disclose confidential business information beyond what is necessary to provide the Services

5. Photographs and Personnel Information

5.1. Many features of the Services involve capturing photographs that may contain images, names, signatures, or other identifying information of loaders, drivers, witnesses, or other personnel.

5.2. Your Responsibility: When you submit photographs containing identifiable individuals, you represent that you have obtained any necessary consents from those individuals to capture, store, and share their images and information through the Services.

5.3. How We Use Photos: Photos may be stored as part of inspection records, safety documentation, load documentation, and claim records. They may be shared with relevant counterparties as described in Section 4.

5.4. AI Training: Photos may be used in aggregated, anonymized form to train and improve our AI models. We do not use identifiable images of individuals to train models without consent.

6. International Data Transfers

6.1 Cross-Border Processing

Your information may be transferred to and processed in countries other than your country of residence, including the United States, for the purposes described in this Privacy Policy.

6.2 Transfer Safeguards

When transferring data internationally, we implement appropriate safeguards, including:

• Adequacy Decisions: Transfers to countries with adequate data protection

• Standard Contractual Clauses: EU-approved contract terms for data protection

• Binding Corporate Rules: Internal privacy standards for corporate transfers

• Consent: Your explicit consent for certain transfers

6.3 Data Localization

Where required by local law, we maintain data processing facilities in specific jurisdictions and implement data residency requirements.

7. Data Retention

7.1 Retention Periods

• Account Information: Retained while your account is active and for 3 years after closure

• Measurement Data and Inspection Photos: Retained for 5 years for service improvement and industry analysis

• Safety Documentation: Retained for 7 years to support potential safety investigations and audits

• Claims Records: Retained for 7 years (or longer if required by applicable insurance, audit, or legal requirements) to support claim resolution, disputes, and audit trails

• Load Documentation: Retained for 5 years to support potential disputes and audits

• Logistics and Location Data: Retained for 2 years for operational reporting; aggregated and anonymized data may be retained longer

• Usage Analytics: Retained for 2 years for performance optimization

• Communication Records: Retained for 3 years for customer service quality

• Legal Records: Retained as required by applicable laws and regulations

7.2 Deletion Requests

You may request deletion of your personal information, subject to legal retention requirements and legitimate business needs (for example, claims and safety records may need to be retained even after a deletion request). We will delete or anonymize your data within 30 days of a valid deletion request to the extent legally permissible.

8. Your Privacy Rights

8.1 Universal Rights

All users have the right to:

• Access: Request a copy of your personal information

• Correction: Update or correct inaccurate information

• Deletion: Request deletion of your personal information

• Opt-Out: Unsubscribe from marketing communications

8.2 Enhanced Rights (GDPR, CCPA, PIPEDA)

Depending on your location, you may also have:

• Portability: Receive your data in a machine-readable format

• Restriction: Limit how we process your information

• Objection: Object to processing based on legitimate interests

• Non-Discrimination: Equal service regardless of privacy choices

• Automated Decision-Making: Information about and opt-out from automated decisions

8.3 Indonesian User Rights (PDP Law)

Indonesian users have additional rights including:

• Right to withdraw consent for data processing

• Right to file complaints with data protection authorities

• Right to compensation for data protection violations

8.4 Malaysian User Rights (PDPA)

Malaysian users have rights including:

• Right to access personal data and processing information

• Right to correct personal data

• Right to withdraw consent for data processing

• Right to prevent processing for direct marketing

8.5 Exercising Your Rights

To exercise these rights, contact us at privacy@ppimeasure.com. We will respond within:

• 30 days (general requests)

• 1 month (GDPR requests)

• 45 days (CCPA requests, with possible 45-day extension)

9. Cookies and Tracking Technologies

9.1 Types of Cookies We Use

• Essential Cookies: Required for basic Service functionality

• Performance Cookies: Help us understand how you use the Services

• Functional Cookies: Remember your preferences and settings

• Analytics Cookies: Provide insights for service improvement

9.2 Third-Party Cookies

We may use third-party analytics and advertising services that place cookies on your device. These services have their own privacy policies.

9.3 Cookie Controls

You can control cookies through your browser settings, but disabling certain cookies may affect Service functionality.

10. Data Security

10.1 Security Measures

We implement industry-standard security measures including:

• Encryption: Data encrypted in transit and at rest using AES-256

• Access Controls: Role-based access with multi-factor authentication

• Network Security: Firewalls, intrusion detection, and secure protocols

• Regular Audits: Security assessments and penetration testing

• Employee Training: Regular privacy and security training for all staff

10.2 Incident Response

In case of a data breach, we will:

• Contain and assess the incident within 24 hours

• Notify affected users within 72 hours where required by law

• Report to relevant authorities as legally required

• Take corrective measures to prevent future incidents

11. Age Restrictions and Minors

11.1 Age Restrictions

The Services are intended for business and commercial use and are not directed to or intended for use by minors. Users must be at least 18 years of age, or the age of majority in their jurisdiction (whichever is higher), to use the Services. We do not knowingly collect personal information from anyone under 18.

11.2 Discovery of Minor Use

If we discover we have collected information from a person under 18, we will delete such information promptly and terminate any associated account. Parents or guardians who believe their child has provided us with personal information may contact us at privacy@ppimeasure.com.

12. Third-Party Services

12.1 Integrated Services

Our Services may integrate with third-party platforms and services, including carriers, vessel-tracking providers, mapping services, and payment processors. This Privacy Policy does not cover third-party privacy practices.

12.2 Links to External Sites

Our Services may contain links to external websites. We are not responsible for the privacy practices of linked sites.

13. Marketing and Communications

13.1 Marketing Consent

We will only send marketing communications with your explicit consent, which you can withdraw at any time.

13.2 Communication Types

• Service Updates: Essential notifications about your account and Services

• Marketing Communications: Product updates, industry news, and promotional content (opt-in only)

• Research Invitations: Opportunities to participate in user research (optional)

13.3 Opt-Out Options

You can opt out of marketing communications by:

• Clicking unsubscribe links in emails

• Updating your account preferences

• Contacting us at privacy@ppimeasure.com

14. Business Intelligence and Analytics

14.1 Aggregated Data

We may create aggregated, anonymized reports about industry trends, usage patterns, measurement data, logistics performance, and safety patterns that do not identify individual users or companies.

14.2 Research Purposes

Anonymized data may be used for academic research, industry studies, and service improvement initiatives.

15. Changes to This Privacy Policy

15.1 Policy Updates

We may update this Privacy Policy periodically to reflect changes in our practices, legal requirements, or Services.

15.2 Notification of Changes

Material changes will be communicated through:

• Email notification to registered users

• Prominent notice within the Services

• Updated "Last Modified" date on this Privacy Policy

15.3 Continued Use

Continued use of the Services after policy changes constitutes acceptance of the updated Privacy Policy.

16. Jurisdiction-Specific Information

16.1 California Residents (CCPA/CPRA)

California residents have specific rights under the California Consumer Privacy Act, as amended by the California Privacy Rights Act. For CCPA-specific information and requests, contact us at privacy@ppimeasure.com.

16.2 Other U.S. State Residents

Residents of Washington, Oregon, and other U.S. states with comprehensive privacy laws may have additional rights under their respective state statutes. Contact us at privacy@ppimeasure.com to exercise these rights.

16.3 Canadian Residents (PIPEDA)

Canadian residents may file complaints about our privacy practices with the Privacy Commissioner of Canada or relevant provincial privacy commissioner.

16.4 Indonesian Residents (PDP Law)

Indonesian residents may file complaints with the Ministry of Communication and Informatics or relevant data protection authorities.

16.5 Malaysian Residents (PDPA)

Malaysian residents may file complaints with the Personal Data Protection Commissioner.

16.6 EU Residents (GDPR)

EU residents may file complaints with their local data protection authority or the lead supervisory authority.

17. Contact Information

17.1 Privacy Officer

For privacy-related questions, complaints, or requests, contact our Privacy Officer:

Ed Crawford, Privacy Officer

6801 Jefferson St. NE, Ste 150-4014

Albuquerque, NM 87109

Email: privacy@ppimeasure.com

Phone: 505.520.9731

17.2 Data Protection Representative (EU)

EU users who need to contact our Data Protection Representative may reach us at privacy@ppimeasure.com. We will appoint a formal EU representative as required by applicable law.

17.3 General Contact

PPI Measure, LLC