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Introduction

This privacy policy statement (the “Privacy Policy”) addresses the practices of information by Shofur Technologies, LLC (“Shofur”, “we”, “us”, or “our”) collected from users of our mobile phone application “Shofur”, which is available for iOS and Android operating systems (the “Application”). Except as expressly set forth in this Privacy Policy, these provisions are solely intended to address information that we collect via the Application from our users (“Users”, “you”, of “your”), and not user information that we may collect from any off-line sources. This Privacy Policy is incorporated into Shofur’s Terms and Conditions by reference, as if set forth fully therein, which must be reviewed and accepted by you prior to accessing and using the Application.

Collection of Personal Information from PLATFORM Users

Shofur and its affiliates, parent companies, partners, subsidiaries, licensors, third-party content or service providers, distributors, dealers, suppliers, and contractors (“Suppliers”) may collect personally identifiable information that you provide to us via (i) registration forms, (ii) surveys, (iii) applications, (iv) user profile registrations and setups, (v) purchase forms, and (vi) other online and mobile application download or purchase fields, including, but not limited to your name, postal and/or email address(es), telephone, fax or mobile number(s), credit card number(s), bank account details, billing information, and/or other relevant personally identifying information (collectively, the “Personal Information”). You may be required to provide us with the foregoing Personal Information to complete your registration profile(s), access certain features on and through the Application, and/or access and purchase certain goods and services made available to you on the Application. A portion of your Personal Information, while collected by Shofur and our Suppliers, may be stored and maintained by a third-party processor(s), including, but not limited to, a payment-processing center. Shofur currently uses Braintree to process our credit card transactions through the Application. By accessing and using the Application, you agree to also be bound by the terms and conditions of Braintree’s own privacy policy regarding such transactions, which can be found here: https://www.paypal.com/us/webapps/mpp/ua/privacy-full.

We will also (i) collect and track information about you that may not constitute Personal Information, including, but not limited to, your home server domain names, date and time of your visit(s), type(s) of computer(s) and/or mobile telephones you use to access the Application, originating IP address(es), files downloaded, search engine(s) used, operating system(s), information and data on how you use the Application (including the page(s) visited), the specific mobile application platform for users of the Applications, language you use in your web browser(s), operating system(s) on your mobile device(s), your mobile device type and related technical information, your geo-location data, the state or country from which you accessed the Application, the date and the time of a visit to the Application, the number of links you click within the Application, the functions you use on the Application, the specific Services (defined below) that you access and/or purchase, the databases you view and the searches you request on or through the Application, and/or the data you view, save on, or download from the Application (the “User Data”); and (ii) aggregate any such User Data. The User Data is typically collected, analyzed and maintained in aggregated and de-identified formats.

If you do not wish to provide us the Personal Information described above, and/or if you prevent us from collecting and storing the User Data in accordance with this Privacy Policy, you will be unable to register and/or to obtain products or services offered by us and our Suppliers to access, reserve, book, and charter buses and coaches (the “Services”) on and/or through the Platforms. You may choose to opt-out of certain provisions of this Privacy Policy by submitting a request in writing to legal@shofur.com Please note that this opt-out process may take some time to complete, based upon then-current request volume and applicable law(s).

Shofur does not knowingly collect or maintain personal information of anyone under the age of eighteen (18). By agreeing to Shofur’s Terms and Conditions and this Privacy Policy, you represent to us and our Suppliers that you are at least eighteen (18) years of age. If you are not at least eighteen (18) years of age, then you may not access and use the Application.

How we Collect Information

Shofur will collect Personal Information and the User Data (collectively, the “Information”) about you through a variety of means, as described more fully below. Firstly, Shofur will collect the Information you submit to us through registration, application, reservation, booking, input, profile building, and payment forms. Shofur, its Suppliers, and other third parties with whom we work (e.g., service providers, business partners, advertisers and advertising servers) may, from time to time, place, view, and/or use various electronic tools or other similar authenticating or tracking technologies on your devices’ hard drive to collect information.

To assist us with the uses described in this Privacy Policy, User Data collected about your use of the Applications may be combined with Personal Information about you from other online or offline sources. If you prefer that we not combine User Data that has been collected through various electronic tracking tools about your use of the Applications, please contact us at legal@shofur.com. If you prefer, most mobile devices allow you to disable the ability for geo-location information to be collected from your mobile device. However, if you disable such abilities, it is possible that some parts of the Application, the data, information, content, materials and/or Services contained on or accessed through the Application, such as the polls, surveys, contests, and product sales, and certain areas of the Application for which you need to log in, will not function properly.

Use of Personal Information Collected

Shofur and its Suppliers may use the Information collected for various reasons, either on behalf of Shofur or its Suppliers’ own purposes, including, but not limited to: (i) research and analysis; (ii) better service provision for users of the Application and the Services (such as by enabling log-in, providing access to certain sections of Application and individual Services, providing customized content; (iii) compilation and aggregation of anonymous information about usage of the Application and the Services; (iv) provide other statistics, sweepstakes, contests, and/or promotions; (v) allow you to access Shofur’s products, tools, features, and Services; (vi) facilitate renewal of payments and related activities; and/or (vii) conduct other business purposes within the borders of the law.

In addition, Shofure and its Suppliers will use your Personal Information to maintain regular contact with you, but not to market new products and services to you that we think will be of particular interest to you, unless you confirm your willingness via an affirmative opt-in mechanism.

Disclosure of Personal Information

Shofur may share your Information with our Suppliers, specifically those with affiliated websites, platforms, applications, services, and/or portals that are under the common ownership or control of Shofur. Shofur may share with other third parties, such as investors and financial and legal advisers, your Information, but only on an anonymous and aggregate basis.

If you participate in certain features of the Application and the Services available on or through the Application, please note that any Information you or others voluntarily disclose through use of these features and Services becomes available to the public and/or other users whom you have designated. If you choose to provide access to designated individuals, please be aware that any information you post will be visible to such individuals for their use. Shofur is not responsible for the Information that you or others choose to disclose publicly on the Application, and Shofur’s, its Suppliers’, or others’ use of such Information is subject to this Privacy Policy.

Shofur may also disclose your Information to unaffiliated third parties if we believe in good faith that such disclosure is necessary to: (a) comply with the law or in response to a subpoena, court order, government request, and/or other legal process; (b) produce relevant documents or information in connection with litigation, arbitration, mediation, adjudication, government or internal investigations, and/or other legal or administrative proceedings; (c) protect the interests, rights, safety, or property of Shofur, or others; (d) enforce any terms of service on this Application; (e) provide you and other users of this Application with the services or products requested by you and/or the other users, and to perform other activities related to such services and products, including billing and collection; (f) provide you with special offers or promotions from Shofur and its Suppliers that may be of interest to you; and/or (g) operate Shofur’s and its Suppliers’ systems properly.

The collection, further use, and/or disclosure of your Information by Third-Party Providers and/or by other third parties is not the responsibility of Shofur or its Suppliers. Rather, such collection, use, and/or disclosure is governed by the third-party providers’ and other third parties’ privacy policies.

Security of Personal Information

Any Personal Information you provide to Shofur is kept on secure servers. Shofur uses reasonable administrative, technical, personnel, and physical measures (i) to safeguard Personal Information against loss, theft, unauthorized use, disclosure, or modification; and (ii) to ensure the integrity of the Personal Information. To help us protect your privacy, you should maintain the secrecy of your logon ID, password, and any other login credentials you may have set up in connection with your access to and use of the Application and the Services offered through the Application.

Despite Shofur’s and its Suppliers efforts to protect your Personal Information, the confidentiality of any communication or material transmitted to or from Shofur via the Application, the Services, or via e-mail cannot be, and is not, guaranteed. Accordingly, Shofur and its Suppliers are not responsible for the security of information transmitted to or from you via the Internet and/or the Application.

In addition, to protect your Personal Information, never share your password, username, and/or other login credentials with anyone, and if you feel that your password or other secret login credentials have been discovered or compromised, you should change it immediately by logging onto the Application and accessing your profile to change your password or by contacting us at legal@shofur.com.

Comments, Rating, COMMUNICATIONS, Notices and User Content

Users of the Application may be permitted, from time to time, to rate, communicating with other Users regarding, and/or comment on various aspects of the Services. Any materials or comments posted by you to any portion of the Application are public. As such, Shofur assumes (i) no liability for the accuracy of such materials, ratings, communications and/or comments, (ii) no duty to update, monitor, or correct such materials or comments, and (iii) no liability for such communications arising under the laws of copyright, libel, privacy, obscenity, or otherwise. Shofur may, in its sole discretion, delete

Access to and Ability to Correct Personal Information

You may modify, correct, change or update your Personal Information by contacting Shofur at legal@shofur.com. While Shofur will make reasonable efforts to accommodate your request, we also reserve the right to impose certain restrictions and requirements on such access requests, if allowed or required by applicable laws.

Right to Change Privacy POLICY

If you choose to visit and use our Application and/or Services available on or through the Application, your visit and any dispute over privacy is subject to this Privacy Policy and our Terms of Use, including, but not limited to, limitations on damages, resolution of disputes, and application of the law of the State of Delaware. If you have any concern about privacy on the Application and/or the Services available on or through the Application, please contact us with a thorough description, and we will try to resolve it. Our business changes constantly, and both this Privacy Policy and Shofur’s Terms and Conditions will change also. We reserve the right to change this Privacy Policy at any time. We may e-mail periodic reminders of our notices and conditions, but you should check the Application frequently to see recent changes. Unless stated otherwise, our current Privacy Policy applies to all information that we have about you and your account. Your continued used of the Application and/or the Services available on or through the Application shall be interpreted as your acceptance of any such changes and updates to this Privacy Policy.

Your California Privacy Rights

If you are a California resident, California Civil Code Section 1798.83 provides you with the right to request certain information regarding disclosure of your Personal Information to third parties for direct marketing purposes, including a description of the categories of Personal Information, be disclosed. In order to obtain such information, please email your request to legal@shofure.com.

Transfer of Personal Information To Other Countries

Some of the uses and disclosures mentioned in this Privacy Policy may involve the transfer and processing of your Information to and in various countries around the world that may have different levels of privacy protection than your country. By submitting your Personal Information, you consent to such transfers and processing.