Account and Data Deletion

1. Purpose and Scope

This Policy explains how to request deletion of an account and its associated personal data on MovingTruck, a fleet and transportation management platform operated by Delpagroup SA, tax ID (RUT) 78.795.960-1, with registered offices at Santa Clara 301, Oficina 3802, Piso 3, comuna de Huechuraba, Santiago, Chile ("MovingTruck," "we," or "us").

It applies to the web platform (company portal and administration portal) and to the mobile apps MovingTruck Driver, for drivers and mechanics (bundle identifier com.delpagroup.movingtruck.driver), and Moving Truck, for company users (bundle identifier com.delpagroup.app.conductor; for historical reasons that identifier retains the word "conductor," but it corresponds to the operator app).

This Policy supplements the MovingTruck Privacy Policy, available at www.movingtruck.app, and the Terms and Conditions, available at www.movingtruck.app. In the event of any conflict regarding the processing of personal data, the Privacy Policy controls.

2. Who May Request Deletion

• a)Individual users. Any person holding a MovingTruck account — driver, mechanic, operator, or company administrator — may request deletion of their personal data and closure of their account.
• b)Client companies. A company administrator may request closure of the corporate account: access is terminated for all of its users and all data not covered by the exceptions in Section 6 is deleted. Tax and payment records cannot be deleted, nor can records of transactions already executed with counterparties (orders awarded through the marketplace or through tenders, and their supporting evidence), which are retained for the applicable legal and contractual periods.
• c)Individuals without a MovingTruck account. If your data appears on the platform even though you do not hold an account — for example, as the recipient or sender of a shipment, a contact of a client company, or a respondent to a public form — you may likewise exercise your rights through the channels listed in Section 3. In these cases, the client company that uploaded your data is the data controller, and we will forward your request to that company.
• Important note for drivers and mechanics affiliated with a company. MovingTruck acts as a technology provider: the company that engaged us is the controller of the operational data generated in the course of your employment or service relationship (routes performed, deliveries, proof of delivery, forms and checklists, expense reports, and the credentials required by the company or by transportation regulations). Accordingly:
• We can delete or pseudonymize your personal account along with your identification and contact details.
• Operational records belonging to the company are not deleted at the request of a driver or mechanic: they are governed by your relationship with that company and by its legal obligations. In such cases we will refer your request to the responsible company and notify you accordingly, identifying whom to contact.

3. How to Request Deletion

• 3.1What You May Request
• You may request either of two things:
• (i) Deletion of your account and all associated personal data.
• (ii) Deletion of specific data only — for example, your location history, the documents you uploaded, or your conversation history with the artificial intelligence assistant — while keeping your account active.
• Please state which of the two you are requesting.
• If you are affiliated with more than one company, please also state whether you wish to unlink from a single company — in which case your account remains active for the others and only the affiliation and work schedules with the specified company are deleted — or to delete your MovingTruck account in full, which terminates your access with respect to every company you are affiliated with.
• 3.2Channels
• a)Email. Write to contacto@delpagroup.com with the subject line "Account deletion request," stating:
• 1The email address and/or phone number you use to sign in.
• 2Your full name.
• 3The company you are affiliated with, if applicable, and your role: driver, mechanic, operator, or company administrator.
• 4The scope of your request, as described in Section 3.1.
• 5If you are a company administrator: the company's name and tax identification number.
• You do not need to have the app installed, or to reinstall it, in order to submit a request: you can write to the email address above directly from this page.
• b)From the mobile apps. The "Delete my account" option within the apps will be available in a forthcoming version of MovingTruck Driver and Moving Truck, whose release will be announced in the app stores. Until then, requests are handled through channels (a) and (b), which are permanently available.
• 3.3Identity Verification
• Requests must be sent from the email address registered to the account. Where that is not possible, we will verify your identity using a one-time code sent to the phone number registered to your account, by SMS or WhatsApp. Only if neither method is available will we ask you for additional proof of identity; in that case, the document is used solely for verification purposes and is deleted once the request has been processed.
• 3.4Actions You Can Take on Your Own
• The following actions do NOT delete your account or your personal data; they only suspend or limit access. To request deletion, you must use one of the channels described in Section 3.2:
• In the MovingTruck Driver app, under the documents section, you may delete files that you uploaded.
• You may stop receiving push notifications by signing out, which deregisters your device token.
• A company administrator may deactivate your access from the web portal (Settings → Users).

4. Timelines and No Cost

• Acknowledgment of receipt: 2 business days.
• Identity verification and final response: 15 business days.
• Execution of the deletion: 30 calendar days from identity verification.
• Backups: deleted data may persist in our database provider's backups until those backups expire under its retention cycle then in effect of 30 days. During that period the data is out of use: it is neither restored nor processed for any purpose, except in the event of disaster recovery, in which case the deletion is re-applied.
• Access to the platform is blocked immediately upon approval of your request, even though deletion of the underlying records may take the periods indicated above.
• Exercising this right is free of charge and requires no statement of reasons. We do not condition deletion on payment of outstanding amounts or on signing any document, without prejudice to the continuing contractual obligations of the client company.

5. Data That Is Deleted

Deletion is carried out through a combination of erasure and irreversible pseudonymization, as record integrity permits. Where your data is referenced by records the client company is required to retain — for example, cash advances, expense reports, form responses, or orders you created — the record containing it is not deleted: it is permanently severed from your identity so that it can no longer be attributed to you.

Except as set out in Section 6, we irreversibly delete or pseudonymize:

• Identification and contact details: name, email address, phone number, national ID number, country, time zone (both self-declared and detected from the device), and profile photo.
• Credentials and sessions: password (stored as a hash), active sessions, IP addresses and device information associated with the session, and one-time code verification attempts (phone number, IP address, and user agent).
• Devices: push notification tokens and device data (make, model, operating system, and app version).
• Personal geolocation: see Section 7.
• Personal documents and files: driver or mechanic validation documents (licenses, certificates, and other requirements imposed by the company or by transportation regulations), your handwritten signatures, and evidence photographs in which you are identifiable. Deletion covers both the database record and the stored file. So long as a file has not been removed from storage, its direct link may remain accessible to anyone holding it; for that reason, removal of the file is part of the deletion procedure itself and not a subsequent step.
• Form and checklist responses in which you appear as an identified respondent (respondent name, email, and phone number).
• Expense reports submitted by you, including the receipt image and the location where the report was recorded, subject to the accounting retention periods in Section 6.
• Conversations with the artificial intelligence assistant: your queries and the responses you received cease to be associated with your user account and are removed from the history available to you. Technical execution logs (token consumption, cost, and latency) are retained severed from your identity, for the company's consumption monitoring. Please note that the content of your queries was processed by our artificial intelligence provider, subject to that provider's retention periods.
• Communication and scheduling records: the history of notifications sent to your name, email, or phone number — including message content — connection alerts associated with your contact details, pending invitations sent to your email address, and your name where it appears as the driver on a dock appointment. Some of these records are stored as free text and are not linked to your account, so their removal is carried out through a targeted search based on the contact details you provide in your request.
• Public tracking links: the links your company shares with its customers display shipment progress. Once your account is deleted, we no longer associate your name with the events visible through those links.
• Other content referring to you: your data included in contact records or other entries that do not constitute the company's operational documentation.

6. Data That Is Retained and Why

We are unable to delete the following data. We will retain it for the period indicated in each case:

• Where retention is mandatory, we sever the record from your identity or pseudonymize it wherever technically feasible — that is, we replace your identifying details with an identifier that on its own does not allow you to be recognized. This applies in particular to records in which you appear as the holder of a cash advance wallet or of an expense report, which accounting rules require us to keep.
• As to aggregate operational metrics: they are retained without identifying you, and upon deletion of your account the driver-vehicle assignment records that would allow them to be linked to you are removed.

7. Geolocation Data

MovingTruck Driver app (drivers and mechanics). Records device location in the background while a shift is active, in order to show the company and its customers the progress of a shipment. Location is captured approximately every 60 seconds or every 100 meters traveled, and stops automatically when the shift is closed.

Moving Truck app (company users). Does not perform background tracking: it captures location in the foreground only, at the moment you record a pickup or a delivery, or complete a location field on a form, and only after you accept the consent notice displayed the first time.

Expense reports. When you submit an expense, the app records the location (coordinates, country, and city) where the report was made. That data forms part of the accounting record and is retained together with the expense report in accordance with Section 6, severed from your identity wherever possible.

Vehicle positions. We also record vehicle positions reported by the GPS providers engaged by each company. Those positions are stored against the vehicle's license plate rather than your name; however, while a vehicle is assigned to you, the route traveled under that license plate may be attributed to you through the driver-vehicle assignment record.

Upon deletion of your account:

• The position history linked to you as a driver is deleted or pseudonymized, including your shifts, your last known position, and your vehicle assignment records.
• Vehicle-based positions (by license plate) and shipment tracking events are retained, as they are operational records of the company and its end customers. These events can be viewed by third parties holding the shipment's tracking code, without signing in. The name of the user who recorded each event is removed from those records and from the public tracking view; only the location, date, and shipment details remain.
• Retention of geolocation history while the account remains active: it is retained for a maximum of 12 months, after which it is automatically purged. You may request deletion of your position history older than a given period at any time, through the channels listed in Section 3.

8. Effects of Deletion

• You lose access to the website and the mobile apps; sign-in will no longer work.
• Deletion and pseudonymization are irreversible. Deleted information cannot be recovered, and severed records cannot be re-associated; if you register again later, the new account will be created with none of your previous data.
• You will stop receiving push notifications, emails, SMS messages, and WhatsApp messages from the platform.
• MovingTruck does not currently offer a full account export feature. Before requesting closure, download from each module the reports and files you wish to keep, or request a copy of your data through the channels listed in Section 3; it will be provided in a structured format within 15 business days.
• For a corporate account: the subscription and its automatic renewal are canceled, all of the company's users are deactivated, and access to orders, routes, fleet, tenders, marketplace, forms, and reports is lost. No refunds are issued for the period already invoiced, unless applicable law provides otherwise.
• Freight and truck listings, bids, counteroffers, and tender submissions are retained in full: they are records of the company you belonged to vis-à-vis its commercial counterparties rather than your personal data, and they document transactions already executed. What is removed is your identification as the user who created or managed each record. In performance reviews in which you appear as the driver being rated, the reference to you is deleted and only the company's aggregate rating is retained.

9. Service Providers Involved in Processing

To deliver the service we rely on providers that process personal data on MovingTruck's behalf and under our instructions:

• GPS tracking providers. Each client company contracts its own account with its GPS provider and enters the access credentials into MovingTruck. Those providers are controllers or processors for the client company, not for MovingTruck; we receive fleet positions from them. A request addressed to MovingTruck does not reach data that those providers keep in their own systems: it must be directed to the company that engaged the service.
• Artificial intelligence assistant. It processes the queries you type, the recent conversation history, and the company data required to respond, as well as receipt images when automated reading is requested.
• Email. In addition to delivery, our transactional email provider logs message opens and clicks on links contained in them.
• Advertising identifiers. MovingTruck does not collect your device's advertising identifier (GAID/IDFA), does not track you across third-party apps or websites, does not display advertising, and does not sell your personal data.
• When executing a deletion request, we instruct the providers that store data on our behalf to delete the corresponding data, within their own technical timeframes. Payment, messaging, and email providers may retain records of transactions and deliveries already completed where their own accounting or traceability rules require it, in which case they act as independent controllers.

10. Legal Framework, Rights and Complaints

We process personal data in accordance with Law No. 19,628 and Law No. 21,719 on the protection of personal data of Chile; Law No. 13,709 (LGPD) of Brazil with respect to data subjects in that country; and Regulation (EU) 2016/679 (GDPR) solely with respect to data subjects located in the European Union.

In addition to deletion, you may exercise your rights of access, rectification, objection, restriction and, where applicable, portability by writing to the privacy address given in Section 11. Portability requests are honored by providing a structured file upon request, as the platform does not offer an automated export feature.

You may also object to automated processing and request human review of decisions taken solely by automated means that affect you. At MovingTruck we use automated processing to extract expiration dates from uploaded documents and to recognize expense receipts; in both cases the result is subject to review and modification by a person at your company or on our team before it takes effect.

If you believe your request was not properly handled, you may file a complaint with the competent authority. In Chile, with the Personal Data Protection Agency once it becomes operational under Law No. 21,719 and, in the meantime, by pursuing the remedies provided under Law No. 19,628 before the ordinary courts. In Brazil, with the Autoridade Nacional de Proteção de Dados (ANPD).

11. Contact

• Deletion and privacy requests: contacto@delpagroup.com
• General support: contacto@delpagroup.com
• Data protection officer, if applicable: not appointed; the channel for exercising rights is contacto@delpagroup.com
• Mailing address: Santa Clara 301, Oficina 3802, Piso 3, comuna de Huechuraba, Santiago, Chile