Privacy Policy

Introduction

Winter Express Logistics LLC (“Company,” “we,” “us,” or “our”) respects your privacy and is committed to protecting your personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard information when you participate in our optional SMS (text message) notification service or otherwise interact with us as an employee or Delivery Associate (DA).

This policy applies to personal information collected through our SMS program and related employment communications. It supplements our Employee Handbook and other company policies. Nothing in this policy alters your at-will employment relationship with the Company.

Information We Collect

When you opt in to our SMS notification service, we may collect:

• Your mobile phone number
• Your name (if voluntarily provided or linked from employment records)
• Any replies or responses you send via SMS (e.g., HELP or STOP)
• Message metadata, such as delivery status, timestamps, and interaction data

We may also link this information to basic employment data (such as your schedule or role) solely to deliver relevant notifications.

We do not collect sensitive personal information (such as Social Security numbers, financial data, or health information) through the SMS service unless required by law or for legitimate operational needs (e.g., safety alerts during station closures).

How We Use Your Information

We use the collected information solely for legitimate business purposes, including:

• Sending work-related SMS notifications such as schedule changes, attendance reminders, station closure or operational disruption updates, safety alerts, uniform requirements, payroll notices, and other important company announcements
• Responding to your requests for help or support
• Maintaining records of consent, opt-ins, and opt-outs as required by law (e.g., TCPA compliance)
• Improving our communication processes and ensuring operational efficiency

We do not use your mobile number or SMS data for marketing, advertising, or any non-work-related purposes.

How We Share Your Information

We do not sell, rent, or share your personal information with third parties for marketing purposes. We may share your information only in the following limited circumstances:

• With our SMS service provider (e.g., Twilio) strictly to operate and deliver the SMS service
• With Amazon as required under our DSP Program Agreement (for operational or audit purposes)
• With legal or regulatory authorities if required by law, court order, or government request
• In the event of a business transfer (merger, acquisition, etc.), subject to appropriate protections

Data Security

We take reasonable administrative, technical, and physical measures to protect your personal information from unauthorized access, disclosure, alteration, or destruction. However, no security system is infallible, and we cannot guarantee absolute security.

Data Retention

We retain your mobile phone number and related SMS data only as long as you remain opted in to the service or as required by law for record-keeping (e.g., consent and opt-out records). Once you opt out by replying STOP, we will remove your number from the SMS system promptly, though we may retain minimal records for compliance purposes.

Your Rights and Choices

• Opt-Out: You may stop receiving SMS messages at any time by replying STOP to any message. You will receive one confirmation message, after which no further texts will be sent.
• Access / Correction: You may request access to or correction of your information by contacting HR.
• Questions or Concerns: Contact us using the information below.

Opting out of SMS does not affect your employment status or at-will relationship with the Company. You must still follow all call-in and notification procedures in the Attendance and Punctuality Policy.

Children's Privacy

Our SMS service is not directed to individuals under the age of 18, and we do not knowingly collect personal information from children.

Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of material changes via SMS (if you are opted in), email, or other available channels. Your continued participation after changes constitutes acceptance of the updated policy.

Governing Law

This policy is governed by the laws of the State of Tennessee, without regard to conflict of law principles.