Privacy Policy

1. Identity of the controller and scope of this policy

MovingTruck is a SaaS (software-as-a-service) platform for fleet management, transportation and logistics operations, consisting of: the public MovingTruck website, the web application for corporate customers, the internal administration panel, the Moving Truck mobile application for operator users (the "Operator app"), and the MovingTruck Driver mobile application for drivers and mechanics (the "Driver app").

The platform is operated by Delpagroup SA, taxpayer ID (RUT) 78.795.960-1, with registered offices at Santa Clara 301, Oficina 3802, Piso 3, comuna de Huechuraba, Santiago, Chile ("MovingTruck" or "we").

This policy explains what personal data we process, for what purposes, on what legal basis, with whom we share it, how long we keep it, and how you may exercise your rights. It applies to every individual whose data is processed through the platform: users at corporate customers, drivers and mechanics, business contacts, shipment recipients, and visitors to the public website.

Applicable legal framework: Chilean personal data protection legislation (Law No. 19,628 and Law No. 21,719, which replaces it and creates the Personal Data Protection Agency, as and when it takes effect); Brazilian Law No. 13,709/2018 (Lei Geral de Proteção de Dados, "LGPD") with respect to data subjects and processing located in Brazil; and Regulation (EU) 2016/679 (GDPR) solely where the processing relates to individuals located in the European Union.

This policy is permanently published and accessible without registration at www.movingtruck.app, and can be reached from both mobile applications. The account deletion request page is available at https://www.movingtruck.app/en/account-deletion.

2. When MovingTruck acts as controller and when as processor

This distinction determines where a request should be directed.

• MovingTruck acts as CONTROLLER with respect to:
• Contact and billing data of corporate customers and of the individuals who represent them.
• Data of visitors to the public website and of those who register or request information.
• Data of the administrator accounts that contract the service, including their subscription history, payments and communications.
• Technical records required to operate, secure and bill for the platform.
• The document review and validation carried out by our team: MovingTruck defines the catalogs of documentary requirements by country and by subject type (driver, mechanic, and also company, vehicle and equipment), and its authorized personnel reviews, approves or rejects uploaded documents, recording who carried out the review, when, and with what remarks. In that specific activity MovingTruck does not act solely on the customer's instructions.
• MovingTruck acts as PROCESSOR, on behalf of and under the instructions of the corporate customer that contracted the service, with respect to the data that customer uploads or generates within its own space on the platform. In particular:
• Data of its drivers, mechanics and internal users.
• Validation documents relating to those individuals (identity, licenses, certificates).
• Geolocation of its vehicles and of its drivers' devices.
• Data of its customers, suppliers, contacts, addresses and shipment recipients.
• Forms, checklists, proof of delivery, expense reports and incident records.
• In these cases, the employing or contracting company is the data controller: it determines the purpose, must have a legal basis, must inform its workers, and must handle rights requests in the first instance. MovingTruck processes that data solely to provide the service; it does not use it for its own purposes and does not sell it. If you are a driver, mechanic or operational user and wish to exercise rights over your data, please contact first the company you work for or provide services to; in any event, you may write to us and we will forward your request (see section 12).
• Notwithstanding the above, and regardless of the role MovingTruck holds with respect to any given data, we will handle directly and without any need for the company's involvement requests concerning: deletion of your account and access credentials, deactivation of your device's notification token, revocation of application permissions, and cessation of location collection from your device. We will inform the corporate customer of such requests where they affect delivery of the contracted service.
• Processing carried out by MovingTruck as a processor must be governed by a Data Processing Addendum forming part of the service agreement signed with each corporate customer, setting out documented instructions, security measures, the sub-processor regime, and the obligations of assistance and of return or deletion of the data upon termination of the service.

3. Categories of personal data processed

We process only those categories the platform actually uses.

• 3.1Identification data. Full name, email address, telephone number, identity document number, country, profile picture, assigned role and account status.
• 3.2Credentials and authentication. Password stored as a hash (never in plain text), session and refresh tokens, one-time verification codes (OTP) sent by WhatsApp or SMS and stored only as a hash, IP address and device information associated with each session and verification attempt.
• 3.3Uploaded documents. Validation documents associated with drivers and mechanics (for example, licenses and certifications, according to the catalog of requirements configured by country and by company), including file name, expiration date, review status (pending, approved, rejected, renewal requested, expired), reviewer's remarks, and the identity of the reviewer.
• These documents are reviewed by authorized MovingTruck personnel and by the corporate customer, depending on the requirement concerned. In addition, the expiration date may be extracted automatically from the document itself using an artificial intelligence model; the system records whether the date was entered manually or proposed automatically (see section 8).
• 3.4Employment and operational data. The company or companies the user belongs to, permissions by module, vehicle and equipment assignments, work shifts (start, end, distance traveled and reason for closing), assigned routes and stops, orders performed, checklists and completed forms, and reported incidents.
• This also includes performance evaluations: when a counterparty company rates a service delivered through the platform, it may associate that rating and its comments with the driver who performed the service.
• 3.5Geolocation. See section 4.
• 3.6Operational financial data. Cash advances and expense reports associated with the holder of a wallet (driver, mechanic or operational user), amounts, currency, notes, image of the receipt or invoice, data extracted automatically from the receipt, and the location where the expense was recorded. We do not store card numbers or bank details: corporate customers' payment methods are processed and tokenized directly by the payment provider, from which we retain only an identifier, the card brand, the last four digits and the expiration date.
• 3.7Proof of performance. Photographs and handwritten signatures captured to evidence pickups and deliveries, and files attached to forms, orders and tenders.
• 3.8Device and push notification data. Push notification token, device type, brand, model, operating system and version, application version, detected time zone, and date of last activity.
• 3.9Platform usage. Access logs, actions performed, administrative changes with before-and-after values, notification dispatches (recipient, subject, content and delivery status), and technical synchronization logs for the integrations.
• 3.10Conversations with the artificial intelligence assistant. See section 7.
• 3.11Third-party data uploaded by the corporate customer or provided without a user account. The platform stores data relating to individuals who are not users: business contacts of customers and suppliers (name, email, telephone, job title, address and notes), contacts associated with addresses and with loading or unloading points, data of the sender and final recipient of each shipment, the name of a third-party driver named in a dock appointment, and contact details of service providers and repair shops.
• The platform also allows forms to be published that are accessible without logging in, in which the respondent provides their name, email, telephone and form answers. In all such cases, the party that determines the purpose and must have a legal basis and inform the data subject is the corporate customer that uploads the data or publishes the form.
• 3.12Corporate customer billing data. Legal name, type and number of tax identifier, line of business, address, billing email and telephone, subscription history, invoices and payment status.
• 3.13Sensitive data. We do not deliberately request or process sensitive data such as health, ethnic or racial origin, trade union membership, sexual orientation, or religious or political beliefs. The mobile applications do not perform biometric authentication, do not access Face ID or fingerprint data, and do not generate biometric identification templates.
• The platform does capture handwritten signatures as proof of delivery or acceptance. That signature is used solely to evidence the transaction; it is not used to identify or authenticate the individual and is not subjected to graphometric analysis. Where applicable law classifies a signature as sensitive data, its processing is based on performance of the transportation contract and on the instructions of the controller company.
• If a user voluntarily uploads sensitive information in a free-text field, a document or a photograph, they do so under the responsibility of the company that administers that space.

4. Geolocation: highlighted processing

This section is highlighted because of its sensitivity and its relevance to Google Play and App Store policies.

• 4.1Vehicle location. MovingTruck connects to satellite tracking providers contracted by the corporate customer. Using the credentials the company itself uploads, the platform periodically queries vehicle positions — roughly once every five minutes — or receives them directly from the provider when the provider pushes them.
• We store latitude, longitude, speed, ignition status, odometer, idle time and, depending on the provider, the device's temperature, voltage and battery level, together with the license plate. This data relates to the vehicle; where the vehicle is assigned to an identified driver, the information makes it possible to infer that person's location and is therefore treated as personal data.
• 4.2Device location in the Driver app. This application collects location in the background, even with the screen off or the application closed, while the driver has an active work shift that they themselves started within the application. Capture occurs approximately every 60 seconds or every 100 meters traveled, whichever comes first, and redundant points are discarded when the device has not moved significantly. Points captured offline are queued locally and sent once connectivity is restored.
• Exclusive purposes: tracking progress on assigned routes and orders, reporting shipment status to the company and its customer, verifying compliance with routes and stops, incident response, and the safety of the cargo and of the driver. We do not use location for advertising, we do not sell it, and we do not disclose it to third parties for marketing purposes.
• 4.3Location in the Operator app. This application does not collect background location. It captures location only in the foreground and on a one-off basis, when the user records a pickup or delivery or completes a location field in a form, in order to evidence where the transaction took place. Before the first capture, an explicit consent notice is displayed that the user must accept.
• 4.4Who can see this information. Location is visible to authorized users of the company to which the driver or vehicle belongs, and to companies with which that company has expressly shared fleet resources.
• It is also visible to authorized MovingTruck personnel through the internal administration panel, which provides live monitoring, route history and work shift visibility in order to operate the service, provide support, diagnose integration failures and respond to corporate customer requests. Such access is restricted by role, and relevant administrative actions are recorded in the audit logs.
• In addition, the company may generate shipment tracking links accessible without authentication by anyone holding the tracking code. Those links display the shipment's transit events, including the recorded location, the event's address and city, the license plate of the assigned vehicle, and the name of the person who recorded each event. Historical routes exposed through this channel are sanitized and do not include license plates. The corporate customer decides to whom it provides the tracking code and is responsible for that distribution. If you are a driver or operational user and do not wish your name to appear on your company's public tracking links, please write to us at the address in section 18.
• 4.5The employer's duty to inform. Where use of the application forms part of an employment or service relationship, the employing company is responsible for informing the worker in advance about location tracking, the hours it covers, its purpose and its duration, and for having the appropriate legal basis under applicable labor and data protection law. MovingTruck provides the tool; it neither replaces nor validates that duty.

5. Mobile application permissions

All permissions are requested at the point where the corresponding feature requires them and may be denied or revoked at any time from the device's operating system settings (on Android: Settings → Apps → the app → Permissions; on iOS: Settings → the app). Revoking a permission does not delete data already collected; for that, use the channels described in sections 12 and 13.

Providing this data is technically optional: the application does not force you to grant the permissions. However, denying the location permission prevents the shift route and the location of transactions from being recorded, which may affect compliance with the obligations you have assumed toward the company you work for or provide services to. That relationship is outside MovingTruck's control.

The applications do not request permission to access contacts and do not incorporate analytics or advertising tools. If your device prompts you for a permission not listed in this table, please write to us at the address in section 18.

6. Purposes and legal bases

7. Artificial intelligence assistant

The platform includes a conversational assistant ("Copilot"). When a user uses it:

• The text the user writes, the most recent turns of the conversation, and the results of the queries the assistant runs against the company's own database in order to answer are sent to our language model provider, Anthropic. Those results may include personal data — for example, lists of drivers, users, contacts, addresses, cash advances or vehicle positions belonging to that company.
• In the automated receipt reading flow, the link to the receipt image stored on the platform is sent to the provider, together with the extraction instruction.
• For each conversation, we retain the text submitted by the user (logged up to a maximum of 4,000 characters), the generated response, the queries executed and their results, token consumption and the date. These are associated with the user and their company, and are accessible to that company and to authorized MovingTruck personnel.
• The assistant accesses information only for the user's active company; it cannot query data belonging to other companies.
• We do not use conversations to train our own models.
• We recommend not entering into the assistant any sensitive information that is not necessary for the query.

8. Automated reading of documents and receipts

When a driver's or mechanic's validation document is uploaded, the platform may use a language model to read the document image and automatically propose its expiration date, in order to raise alerts about documents nearing expiry. The same type of automated reading is applied to expense receipts, in order to pre-fill amounts and dates.

This automated reading does not in itself constitute a decision about the individual: approval or rejection of a document is always performed by an authorized person, whose identifier and review date are recorded. If you believe that an automatically extracted item of data is incorrect, you may request its correction from your company or at the address in section 18, and request human review of the outcome.

For this processing, the image of the document or receipt is transmitted to our language model provider identified in section 9.

9. Recipients and processors to whom we disclose data

We do not sell personal data. We disclose it only to those recipients necessary to operate the service. Each provider's terms of service and the confidentiality and data protection commitments that provider offers apply.

The last two rows correspond to third parties contracted or administered by the corporate customer itself, not by MovingTruck: the company selects them, uploads their credentials and is answerable for its relationship with them.

The list above constitutes the roster of authorized sub-processors. We will notify corporate customers at least 30 days in advance before adding or replacing a sub-processor that processes personal data, identifying the service provided and the location of the processing; the corporate customer may raise a reasoned objection to the change within that period.

We may also disclose data to administrative or judicial authorities where there is a legally grounded request, and to legal or accounting advisors bound by a duty of confidentiality.

We do not use web analytics, advertising or third-party measurement tools on the site or in the applications: there is no Google Analytics, Tag Manager, advertising pixels or mobile analytics SDK. The only behavioral measurement carried out is that of our transactional email provider, which by default records email opens and clicks on links, for the purpose of verifying effective delivery of operational communications.

10. International transfers

The platform's infrastructure and the recipients identified in section 9 operate servers outside Chile, principally in the United States and in other regions where those providers deliver their services. As a result, the personal data processed by MovingTruck is transferred to and stored outside the territory in which it was collected, including outside Chile and Brazil.

These transfers are made under the service agreements entered into with each provider and the confidentiality and security safeguards they offer. Under Law No. 21,719 and the LGPD, an international transfer must rely on a recognized mechanism — standard contractual clauses, including the cláusulas-padrão approved by the ANPD for Brazil; a finding of adequate level of protection; or another safeguard accepted by the competent authority.

You may request information about the mechanism applicable to a specific transfer by writing to the address in section 18.

11. Retention periods

We retain data for as long as the corporate customer's agreement remains in force and, thereafter, for the periods required by applicable tax, labor and commercial legislation.

In the interest of transparency, we disclose the following about the current state of the service:

• Vehicle and driver geolocation positions, shipment tracking history and work shift records do not currently have an automatic deletion period configured on the platform, and are therefore retained for as long as the account remains active. The periods we commit to are:
• Driver GPS positions: 12 months
• Vehicle positions and telemetry: 12 months
• Shipment tracking events and work shift records: 12 months
• Conversations with the artificial intelligence assistant are retained with no automatic deletion. MovingTruck has committed to deleting or anonymizing them 12 months after the last message in the conversation
• Validation documents and uploaded files (evidence, signatures, receipts) do not currently have automatic deletion: they are retained even where the individual is disassociated from the company or their account is deactivated, until a deletion is executed upon request. MovingTruck has committed to retaining them for a maximum of 12 months from the person's disengagement or the deactivation of their account
• Technical synchronization logs for the tracking integrations are deleted automatically after 7 days.
• Sessions expire and are deleted upon expiry or upon logout.
• Orders, routes, forms, expense reports and billing records are retained for accounting and operational traceability reasons. MovingTruck retains them for 6 years from the close of the relevant accounting period

12. Individual rights and how to exercise them

You may exercise the rights of access, rectification, deletion or cancellation, objection, portability, and blocking or temporary restriction of processing while a rectification or deletion request is pending, as well as the right not to be subject to decisions based solely on automated processing that produce legal effects or significantly affect you, under Chile's Law No. 19,628 and Law No. 21,719.

If you are located in Brazil, the LGPD additionally grants you the rights to confirmation that processing exists, anonymization or blocking of data processed in excess, information about the public and private entities with which we share your data, information about the possibility of withholding consent and the consequences of doing so, withdrawal of consent, and review of automated decisions. Where applicable, the rights granted by the GDPR will also apply.

Channel: write to contacto@delpagroup.com, stating your name, the company through which you use the platform, the right you are exercising and a description of your request. We may ask you to verify your identity before responding.

Response time: we will acknowledge receipt within 2 business days and will respond within the applicable statutory period, which will in no case exceed 15 days for data subject access requests in Brazil (LGPD, article 19).

If you consider that your request was not properly handled, you may complain to the competent supervisory authority: in Chile, the Personal Data Protection Agency created by Law No. 21,719; in Brazil, the Autoridade Nacional de Proteção de Dados (ANPD).

Data Protection Officer (referred to as encarregado under Brazil's LGPD). Under article 41 of the LGPD, the controller must appoint the person responsible for handling communications from data subjects and from the ANPD and publish their contact details: as of this version no encarregado has been appointed for the Brazilian operation; communications are received at contacto@delpagroup.com. As regards Chile: no Data Protection Officer has been appointed; the channel for exercising rights is contacto@delpagroup.com.

13. Account deletion

• 13.1How to request it
• 1By email: write to contacto@delpagroup.com from the address associated with your account, with the subject line "Account deletion". This is currently the channel available to data subjects.
• 2State your name, the account email address and the company through which you access the platform.
• 3We will confirm receipt and verify your identity.
• 4We will process the request within 30 calendar days.
• 13.2What happens when the request is processed
• Immediately: your account is deactivated, you lose access to the platform and the applications, your active sessions are terminated, your schedules and shifts are turned off, your location ceases to be collected, and you can no longer be assigned to routes or tasks. Your device's notification token is deactivated when you log out of the application.
• Thereafter: deletion or anonymization of your identification data, your validation documents — including stored files — and your position and work shift history is carried out through an internal procedure managed on request, and not automatically.
• What is retained: certain records cannot be deleted without destroying the traceability of operations already performed or the accounting records required by law. In particular: orders and routes actually performed, proof of delivery, expense reports and cash advances already settled, accounting and tax documentation, and audit logs. In those cases your identity is replaced by an internal identifier where technically feasible; where it is not, the data is retained for the applicable statutory period and then deleted.
• If you are a user of a corporate customer, that company's administrator may also deactivate your access from the users module; such deactivation is not equivalent to the deletion described in this section.

14. Information security

We apply reasonable technical and organizational measures, including:

• Encryption in transit via HTTPS/TLS for all communications between the applications, the website and our services.
• Passwords and verification codes stored as hashes using the bcrypt algorithm: they are not stored in plain text and are not reversible, not even by us. Verification codes expire once used or when their validity period lapses.
• Token-based authentication with expiration, controlled renewal and session revocation.
• Role-based access control with a privilege hierarchy verified on every request, and granular per-module permissions for operational users and drivers.
• Isolation between companies: each request is resolved against the user's active company; one company's data is not accessible from another company's space, except where the company itself expressly shares fleet resources.
• Encryption of integration credentials for satellite tracking and customers' external systems stored on the platform.
• Tokenization of payment methods by the payment provider; we do not store full card numbers.
• Audit logs of relevant administrative actions, with before-and-after values.
• File storage. Documents, evidence, signatures and receipts are hosted in our infrastructure provider's storage. Access to those files is currently by means of direct links that do not require logging in; the addresses are neither listable nor indexed and are provided only to authorized users within the platform.
• Infrastructure managed on cloud providers with their own security controls.
• No system is completely invulnerable. If we detect a security incident affecting personal data, we will notify the corporate customer responsible for that data and the competent supervisory authority — in Chile, the Personal Data Protection Agency; in Brazil, the ANPD — without undue delay. Where the incident may significantly affect individuals' rights, we will also notify the affected data subjects directly, describing the nature of the incident, the data involved, the measures taken and the applicable recommendations. Where MovingTruck acts as processor, that communication will be coordinated with the controller company, without such coordination delaying notification to the authority.

15. Minors

MovingTruck is a professional tool intended for companies and for adults working in the transportation and logistics sector. It is not directed at minors and we do not knowingly collect data from persons under 18 years of age. If we learn that an account has been created for a minor, we will deactivate it immediately and process the deletion of their data under the procedure in section 13. If you are a parent or guardian and believe that a minor has provided us with data, please write to the address in section 18.

16. Cookies and similar technologies

The platform does not use advertising, analytics or third-party tracking cookies. The only cookies we set are strictly functional:

The approximate country used to preselect the language is obtained from a header added by our web hosting provider based on the connection's IP address. The device's location is not accessed, the IP address is not stored for that purpose, and the result determines only the initial interface language.

In addition, the web application uses the browser's local storage (localStorage) to hold session tokens and basic user data while the session is active; this is not a cookie and is not transmitted to third parties. It is cleared on logout.

Maps on the website and in the web application load tiles from external map providers (OpenStreetMap and CARTO), and address searches query the Nominatim service; in both cases those third parties receive the browser's IP address.

You may block or delete cookies from your browser settings; blocking the functional cookies will only mean having to select the language on each visit.

17. Changes to this policy

We may update this policy to reflect changes in the platform, in the providers used, or in applicable regulations. The version in force will always be published at the address indicated in section 1, showing its last-updated date. Where changes are substantial — for example, new categories of data, new purposes or significant new processors — we will notify corporate customers at least 30 days in advance by email and through a notice within the platform.

18. Contact

• Inquiries and exercise of rights: contacto@delpagroup.com
• Service support: contacto@delpagroup.com
• Address for notices: Santa Clara 301, Oficina 3802, Piso 3, comuna de Huechuraba, Santiago, Chile
• Controller: Delpagroup SA
• Data Protection Officer / encarregado: not appointed; requests are directed to contacto@delpagroup.com

19. Governing law and jurisdiction

This policy and the processing of personal data described in it are governed by the laws of the Republic of Chile. Any dispute will be submitted to the ordinary courts of justice of Santiago, Chile, without prejudice to the data subject's right to turn to the supervisory authority of their country of residence.