Privacy Policy

1. Introduction

Workhorse, Inc. (“Workhorse,” “we,” “us,” or “our”) is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your personal information when you use our website, applications, and vehicle leasing services (collectively, the “Services”).

By using our Services, you consent to the collection and use of your information as described in this Privacy Policy. If you do not agree with our practices, please do not use our Services.

2. Information We Collect

We collect the following categories of personal information:

2.1 Information You Provide

• Account Information: Full name, email address, phone number, date of birth, mailing address, emergency contact information
• Identity Documents: Driver's license images (front and back), gig platform account proof
• Payment Information: Credit/debit card details, bank account information (processed and stored securely by Stripe — we do not store your full payment card number)
• Communications: Messages, support requests, and feedback you send to us
• Vehicle Requests: Vehicle preferences, special requests, and delivery instructions

2.2 Information Collected Automatically

• Vehicle Data: GPS location, vehicle diagnostics, mileage, and immobilizer status collected through Samsara devices installed in all Workhorse vehicles
• Usage Data: Pages visited, features used, click patterns, session duration, and interaction data
• Device Data: Browser type, operating system, IP address, device identifiers, and screen resolution
• Cookies & Similar Technologies: We use cookies, web beacons, and similar technologies to enhance your experience and collect usage data

2.3 Information from Third Parties

• Payment Processor (Stripe): Payment status, transaction confirmations, and billing information
• E-Signature Provider (DocuSign): Signature status and signed document records
• Fleet Management (Samsara): Vehicle location, diagnostics, and status data

3. How We Use Your Information

We use your personal information for the following purposes:

3.1 Service Delivery

• Processing and evaluating your lease application
• Verifying your identity and eligibility
• Managing your vehicle lease and account
• Processing weekly payments through Stripe
• Facilitating electronic lease signing through DocuSign
• Coordinating vehicle pickup or delivery
• Providing customer support

3.2 Fleet Operations & Safety

• Fleet management and vehicle tracking through Samsara
• Vehicle recovery in case of theft or payment default
• Scheduling preventive maintenance
• Safety monitoring and emergency response
• Vehicle immobilization in cases of payment default (with prior notice)
• Geofence monitoring and work area compliance verification

3.3 Communication

• Sending application status updates and account notifications
• Payment reminders and billing notifications
• Service announcements and platform updates
• Responding to your inquiries and support requests

3.4 Improvement & Analytics

• Analyzing usage patterns to improve our Services (via PostHog)
• Monitoring and resolving technical issues (via Sentry)
• Developing new features and services
• Conducting internal research and analysis

4. Vehicle GPS Tracking

All Workhorse vehicles are equipped with GPS tracking devices operated through Samsara. Vehicle location data is collected continuously while the vehicle is in your possession and is used for:

• Fleet management and operational logistics
• Vehicle recovery in case of theft or payment default
• Safety and emergency response coordination
• Preventive maintenance scheduling based on vehicle diagnostics
• Verification of vehicle location for insurance and safety purposes
• Geofence monitoring to ensure vehicles remain within the designated operating area

GPS tracking is an essential part of our fleet management operations and cannot be disabled or opted out of during the term of your lease. This is disclosed in your Vehicle Lease Agreement and these privacy terms.

5. Vehicle Immobilization

In cases of payment default or serious lease violations, Workhorse may remotely immobilize vehicles through Samsara's immobilizer system. This capability is governed by the following safeguards:

• You will always receive advance written notice before immobilization is initiated
• A grace period will be provided to resolve the underlying issue
• Immobilization will not be initiated while the vehicle is in motion
• All immobilization actions are logged in our audit system with the reason and authorizer
• You may contact support to discuss and resolve the matter

6. Third-Party Services

We share your information with the following trusted service providers, each of whom has their own privacy policy:

We do not sell, rent, or trade your personal information to third parties for marketing purposes. Information is shared with third parties only as described in this policy or with your explicit consent.

7. Data Retention

We retain your personal information according to the following schedule:

• Active lease period: All account and vehicle data is retained for the duration of your lease
• Post-lease: Account and lease data is retained for 7 years after lease termination for legal, regulatory, and audit compliance
• Vehicle GPS data: Location data is retained for 12 months, then automatically purged
• Analytics data: Anonymized usage data may be retained indefinitely for aggregate analysis
• Support communications: Retained for 3 years after the last interaction

You may request deletion of your account data by contacting support, subject to our legal retention obligations. Some data may be retained in anonymized form for analytical purposes.

8. Your Rights

Depending on your location and applicable law, you may have the following rights regarding your personal information:

• Right to Access: Request a copy of the personal data we hold about you
• Right to Correction: Request correction of inaccurate or incomplete personal data
• Right to Deletion: Request deletion of your personal data, subject to legal retention requirements
• Right to Portability: Receive your personal data in a structured, machine-readable format
• Right to Object: Object to certain processing activities, such as direct marketing
• Right to Opt Out: Opt out of marketing communications at any time via your account settings or the unsubscribe link in emails
• Right to Non-Discrimination: We will not discriminate against you for exercising your privacy rights

To exercise any of these rights, contact us through our support page or email us at privacy@workhorsevehicles.com. We will respond to your request within 30 days.

9. California Privacy Rights (CCPA)

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA):

• The right to know what personal information we collect, use, and disclose
• The right to request deletion of your personal information
• The right to opt out of the sale of your personal information (note: we do not sell personal information)
• The right to non-discrimination for exercising your CCPA rights

To submit a CCPA request, contact us at privacy@workhorsevehicles.com or through our support page. We may need to verify your identity before processing your request.

10. Cookies & Tracking Technologies

We use the following types of cookies and tracking technologies:

• Essential Cookies: Required for the basic functionality of our platform (authentication, security)
• Analytics Cookies: Help us understand how users interact with our Services (PostHog)
• Marketing Cookies: Used to track the effectiveness of our advertising campaigns (UTM parameters)

You can control cookie preferences through your browser settings. Disabling certain cookies may affect the functionality of our Services.

11. Security

We implement industry-standard security measures to protect your personal information, including:

• Encryption of data in transit (TLS/SSL) and at rest
• Access controls and role-based permissions for internal staff
• Regular security audits and vulnerability assessments
• PCI DSS compliant payment processing through Stripe
• Secure, encrypted storage of sensitive documents
• Automatic session timeouts and multi-factor authentication options

While we strive to protect your personal information, no method of electronic transmission or storage is 100% secure. We cannot guarantee absolute security but are committed to implementing best practices to minimize risk.

12. Children's Privacy

Our Services are not intended for individuals under the age of 21. We do not knowingly collect personal information from anyone under 21. If we learn that we have collected personal information from someone under 21, we will take steps to delete that information as quickly as possible.

13. International Data Transfers

Your information may be processed and stored in the United States and other countries where our service providers operate. By using our Services, you consent to the transfer of your information to the United States and other jurisdictions, which may have different data protection laws than your country of residence.

14. Changes to This Policy

We may update this Privacy Policy from time to time. If we make material changes, we will notify you by email, through the Services, or by posting a prominent notice on our website. The “Last updated” date at the top of this policy indicates the most recent revision. Your continued use of the Services after any changes constitutes acceptance of the updated policy.

15. Contact Information

For privacy-related questions, to exercise your rights, or to file a complaint, you may contact us:

• Through our support page
• By email: privacy@workhorsevehicles.com

We will respond to all privacy-related inquiries within 30 days of receipt.