Effective Date: 1st June 2026

1. Introduction

Freeflow Transport Services (“Freeflow”, “we”, “our”, or “us”) is committed to protecting the privacy, confidentiality, and security of the information entrusted to us by our customers, business partners, suppliers, contractors, and authorized representatives.

This Commercial Privacy Policy describes how Freeflow collects, uses, discloses, stores, and safeguards information obtained through our transportation, logistics, freight, passenger transportation, dispatch, fleet management, and related commercial services.

Freeflow provides services throughout Canada and the United States and may expand into additional jurisdictions where permitted by law.

This Policy applies primarily to business-to-business (B2B) relationships, including commercial customers, corporate clients, logistics partners, and authorized representatives acting on behalf of an organization. Where applicable laws classify business contact information or employee information as personal information, Freeflow will handle such information in accordance with this Policy and applicable privacy legislation.

By using our services, website, portals, applications, or communicating with Freeflow, you acknowledge and agree to the collection, use, disclosure, and retention practices described in this Policy.

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2. Information We Collect

We collect information necessary to establish, maintain, administer, and fulfill our commercial transportation and logistics services.

Corporate Information

We may collect:

• Legal business name

• Trade name

• Business registration information

• Tax identification numbers

• Billing and mailing addresses

• Insurance information

• Licensing and regulatory documentation

Authorized Representative Information

We may collect:

• Full names

• Business email addresses

• Business telephone numbers

• Job titles

• User account credentials

• Account authorization levels

• Communication preferences

Transportation and Operational Information

We may collect:

• Pickup and delivery locations

• Freight descriptions

• Shipment information

• Passenger manifests

• Bills of lading

• Routing information

• Scheduling requirements

• Delivery confirmations

• Electronic signatures

• Dispatch records

• Vehicle assignment records

Financial Information

We may collect:

• Banking information

• ACH/EFT payment details

• Credit references

• Billing records

• Commercial payment history

• Payment card information processed through authorized payment providers

Technical and Usage Information

When using our website, portals, mobile applications, or technology platforms, we may collect:

• IP addresses

• Device identifiers

• Browser information

• Operating system information

• Login activity

• Session logs

• Website usage data

• Application usage data

• Security monitoring records

Fleet and Telematics Information

Where applicable, we may collect:

• GPS location information

• Fleet telematics data

• Vehicle performance data

• Driver activity records

• Electronic logging data

• Asset tracking information

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3. How We Use Information

Freeflow uses collected information for legitimate business purposes, including:

Service Delivery

• Providing transportation and logistics services

• Scheduling and dispatching vehicles

• Managing freight and passenger transportation

• Tracking shipments and deliveries

• Coordinating logistics operations

Account Administration

• Creating and managing customer accounts

• Processing payments and invoices

• Managing credit arrangements

• Providing customer support

• Maintaining business records

Communications

• Sending operational notifications

• Providing service updates

• Communicating safety alerts

• Delivering account-related notices

• Responding to inquiries

Security and Fraud Prevention

• Verifying identities and authorizations

• Detecting fraud or unauthorized activity

• Protecting company assets

• Protecting technology systems and networks

• Conducting internal investigations

Legal and Regulatory Compliance

• Complying with transportation regulations

• Meeting customs requirements

• Satisfying tax obligations

• Responding to lawful requests from authorities

• Maintaining required records

Business Operations and Improvement

• Improving service quality

• Analyzing operational performance

• Developing new products and services

• Managing business risks

• Conducting internal reporting and analytics

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4. Legal Basis for Processing

Where required by applicable law, Freeflow processes information based on one or more of the following legal grounds:

• Performance of a contract;

• Compliance with legal obligations;

• Legitimate business interests;

• Protection of legal rights;

• Consent, where required by law.

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5. How We Share Information

Freeflow does not sell personal information or confidential commercial information.

We may share information with the following categories of recipients:

Transportation and Logistics Partners

Information may be shared with:

• Independent contractors

• Drivers

• Carriers

• Freight providers

• Customs brokers

• Third-party logistics providers

• Dispatch partners

where necessary to fulfill transportation services.

Service Providers

Information may be shared with service providers that support our operations, including:

• Cloud hosting providers

• Software vendors

• Payment processors

• Mapping and routing providers

• Telecommunications providers

• Security service providers

• Professional advisors

Government Authorities

Information may be disclosed when required or permitted by law to:

• Customs authorities

• Transportation regulators

• Tax authorities

• Courts

• Law enforcement agencies

• Regulatory bodies

Corporate Transactions

Information may be disclosed in connection with:

• Mergers

• Acquisitions

• Asset sales

• Financings

• Corporate restructurings

• Business transfers

where permitted by law.

Mobile Information and SMS Communications

Freeflow may collect mobile telephone numbers and related consent information where customers, authorized representatives, or users choose to receive SMS or text message communications.

No mobile information will be shared with third parties or affiliates for marketing or promotional purposes.

Notwithstanding any other provision of this Privacy Policy, all categories of information described herein exclude SMS text messaging originator opt-in data and consent records. SMS opt-in information, consent records, and related mobile messaging data will not be sold, rented, shared, disclosed, or otherwise transferred to any third parties for marketing, promotional, or advertising purposes.

Freeflow may share mobile information only with service providers that assist in the delivery of SMS communications on our behalf and solely to the extent necessary to provide such services. Such providers are contractually required to maintain the confidentiality and security of the information and are prohibited from using it for any other purpose.

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6. Cross-Border Data Transfers

Because Freeflow operates throughout Canada and the United States, information may be transferred, processed, accessed, or stored in multiple jurisdictions.

Information may be processed by Freeflow, its affiliates, subcontractors, logistics partners, or technology providers located in Canada, the United States, or other jurisdictions where Freeflow conducts business.

Information transferred across borders may be subject to the laws and lawful access requirements of the receiving jurisdiction.

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7. Cookies and Website Technologies

Freeflow may use cookies, analytics tools, web beacons, and similar technologies on its websites, portals, and applications.

These technologies may be used to:

• Operate and secure our services;

• Authenticate users;

• Improve functionality;

• Analyze website performance;

• Monitor system usage;

• Detect fraud and unauthorized access.

Users may manage cookie preferences through browser settings. Certain website features may not function properly if cookies are disabled.

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8. Data Security

Freeflow maintains administrative, technical, organizational, and physical safeguards designed to protect information against:

• Unauthorized access;

• Unauthorized disclosure;

• Loss;

• Theft;

• Misuse;

• Alteration;

• Destruction.

Security measures may include:

• Access controls;

• Password protection;

• Encryption technologies;

• Network monitoring;

• Employee training;

• Vendor security reviews.

While Freeflow uses commercially reasonable safeguards, no transmission or storage method can be guaranteed to be completely secure.

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9. Data Retention

Freeflow retains information only as long as reasonably necessary to:

• Provide services;

• Manage customer relationships;

• Meet legal obligations;

• Resolve disputes;

• Enforce agreements;

• Maintain operational records.

Retention periods may vary depending on applicable transportation, customs, accounting, tax, insurance, safety, and regulatory requirements.

When information is no longer required, it may be securely deleted, anonymized, archived, or otherwise disposed of in accordance with applicable laws and business practices.

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10. Your Privacy Rights

Subject to applicable laws, individuals may have the right to:

• Request access to personal information;

• Request correction of inaccurate information;

• Request deletion of certain information;

• Request information regarding processing activities;

• Withdraw consent where processing relies on consent;

• Submit privacy-related complaints.

Freeflow will respond to applicable requests within the timeframes required by law.

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11. Applicable Privacy Laws

Freeflow strives to comply with applicable privacy and data protection laws, including, where applicable:

• The Personal Information Protection and Electronic Documents Act (PIPEDA);

• Provincial privacy legislation;

• Applicable United States federal privacy requirements;

• Applicable state privacy laws, including the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA);

• Transportation, customs, and regulatory requirements applicable to our operations.

Nothing in this Policy limits any rights that individuals may have under applicable law.

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12. Data Breach Response

If Freeflow becomes aware of a security incident involving information under its control, Freeflow will investigate the matter and take appropriate remedial measures.

Where required by applicable law, Freeflow will provide notice to affected individuals, customers, regulators, or authorities.

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13. Third-Party Websites

Freeflow’s website, portals, or applications may contain links to third-party websites or services.

Freeflow is not responsible for the privacy practices, content, security, or policies of third-party websites or services. Users should review the privacy policies of any third-party websites they access.

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14. Changes to This Policy

Freeflow may update this Privacy Policy from time to time.

Any updates will be posted on our website together with a revised Effective Date.

Continued use of our services following publication of changes constitutes acceptance of the updated Policy.

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15. Governing Law

This Privacy Policy shall be governed by and interpreted in accordance with the laws of Manitoba, Canada, except where mandatory laws of another jurisdiction apply.

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16. Contact Information

For privacy-related inquiries, requests, complaints, or questions regarding this Privacy Policy, please contact:

Privacy Officer
Freeflow Transport Services

Head Office: Winnipeg, Manitoba, Canada

Email: info@freeflowtransport.ca

Website: www.freeflowtransport.ca

Freeflow will make reasonable efforts to respond to privacy inquiries in a timely manner and in accordance with applicable legal requirements.