BRILLIANTMOVE

Privacy Policy

Effective Date: May 27, 2026

Version 4.0

Your Privacy Matters

This policy explains how BrilliantMove collects, uses, and protects your information.

1.  About This Policy

BrilliantMove, Inc. operates a software and logistics coordination platform (the “Platform”) that facilitates operational coordination, delivery scheduling, route visibility, payment facilitation, and communications among customers, retailers, delivery providers, and operational users. This Privacy Policy describes how BrilliantMove collects, uses, shares, retains, and protects personal and operational information in connection with Platform operations.

This Policy applies to all users of the Platform including consumers, delivery providers, retailers, and business account users. By accessing or using the Platform, you acknowledge and agree to the data practices described in this Privacy Policy.

1.1  Role-Based Privacy Framework

BrilliantMove serves multiple categories of users with distinct data practices. This Policy is organized as follows:

• Part A: Consumers and Customers
• Part B: Delivery Providers and Drivers
• Part C: Retailers and Business Users
• Part D: General Operational Data Practices (applicable to all roles)

PART A: Consumer and Customer Privacy

This section applies to end consumers placing delivery orders or receiving deliveries through the Platform.

A.1  Information We Collect from Consumers

BrilliantMove collects the following categories of information from consumers:

• Identity and Contact Information: full name, email address, mobile telephone number, and delivery address(es);
• Delivery Information: recipient names, delivery addresses, access codes, special delivery instructions, and order contents as submitted;
• Transaction Data: order history, payment metadata (we do not store full payment card numbers), transaction amounts, and refund or dispute records;
• Device and Technical Data: device type, operating system, application version, IP address, and session data;
• Communications Data: customer support interactions, chat records, complaint submissions, and SMS correspondence;
• Preference Data: delivery preferences, communication preferences, and opt-in/opt-out records.

A.2  How We Use Consumer Information

BrilliantMove uses consumer information for the following purposes:

• coordinating and facilitating delivery scheduling, routing, and completion;
• sending transactional SMS and email notifications regarding delivery status, ETA updates, and order events;
• processing payments and managing payment disputes;
• providing customer support and resolving disputes;
• detecting and preventing fraud or Platform abuse;
• improving Platform performance, reliability, and user experience;
• complying with applicable legal obligations.

A.3  No Advertising Profiling

BrilliantMove does not build advertising profiles, behavioral advertising data sets, or third-party marketing data using consumer personal information. Consumer data is used exclusively for operational Platform purposes.

BrilliantMove does not sell consumer personal information to advertisers, data brokers, or marketing platforms. BrilliantMove does not use consumer activity data to build behavioral advertising profiles. Consumer information is collected and used solely to operate the Platform, facilitate deliveries, and improve Platform functionality.

A.4  Consumer Information Shared with Providers

To facilitate delivery operations, BrilliantMove shares limited consumer information with assigned delivery providers, including: recipient name, delivery address, access instructions, and contact phone number for delivery coordination only. This sharing is operationally necessary and limited to what is required to complete the delivery.

A.5  Consumer Rights

Depending on applicable law, consumers may exercise the following rights regarding their personal information:

• Right of Access: request a copy of personal information BrilliantMove holds about you;
• Right of Correction: request correction of inaccurate or incomplete personal information;
• Right of Deletion: request deletion of personal information, subject to legal retention obligations;
• Right to Opt-Out of Communications: opt out of non-essential communications at any time;
• Right to Data Portability: where applicable under law, request personal information in a portable format;
• Right to Limit Use of Sensitive Personal Information: where applicable under state law.

To exercise these rights, contact: privacy@mybrilliantmove.com.

A.6  State Privacy Law Compliance

BrilliantMove acknowledges applicable state privacy laws, including the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA), Virginia Consumer Data Protection Act (VCDPA), Colorado Privacy Act (CPA), Connecticut Data Privacy Act (CTDPA), and similar laws in other states. BrilliantMove does not sell personal information as defined under applicable state law. To submit a state privacy rights request, contact: privacy@mybrilliantmove.com.

PART B: Delivery Provider and Driver Privacy

This section applies to independent delivery providers, drivers, couriers, and independent logistics operators using the Platform.

B.1  Information We Collect from Providers

BrilliantMove collects the following categories of information from providers:

• Identity and Onboarding Information: full name, contact details, business entity information (if applicable), government-issued identification, and banking information for payout processing;
• Operational Availability Data: scheduling availability, active session data, and assignment acceptance/rejection records;
• GPS and Location Data: real-time GPS coordinates, route telemetry, stop records, and travel path data during active Platform sessions;
• Assignment and Performance Data: assignment history, completion records, delivery confirmation data (including photographs and electronic signatures), and operational performance metrics;
• Device Data: device identifiers, mobile application version, and device performance data;
• Communications Data: SMS correspondence, in-app messaging, and support interactions;
• Payment Metadata: payout records, transaction history, and earnings data.

B.2  GPS and Location Tracking

Providers expressly consent to GPS location tracking during active Platform sessions as a condition of Platform access and assignment eligibility. This collection is operationally necessary for core Platform functions.

BrilliantMove collects foreground and background GPS location data from delivery providers during active operational workflows. This collection is operationally necessary for real-time route optimization and navigation assistance; ETA generation and communication to customers and retailers; delivery completion verification and proof-of-delivery; operational performance monitoring and analytics; fraud detection and GPS spoofing prevention; safety monitoring during active delivery operations; and operational dashboard visibility for authorized Platform users.

Providers may terminate GPS tracking by logging out of the Platform application. Terminating location tracking during an active assignment may impair the provider’s ability to complete that assignment and may result in assignment cancellation.

B.3  Biometric and Photographic Data

BrilliantMove does not use facial recognition technology or biometric identification systems. Proof-of-delivery photographs are used solely for operational delivery verification purposes.

Photographs captured through the Platform as proof-of-delivery records are used exclusively for delivery confirmation, dispute resolution, and operational compliance purposes. BrilliantMove does not apply facial recognition, biometric identification, or similar technology to any photographs collected through the Platform. Electronic signatures collected through the Platform are used solely for delivery verification and are not used for biometric identification purposes. BrilliantMove does not create biometric identifiers or biometric information profiles from any data collected through the Platform.

B.4  Operational Monitoring

Provider activity data, including route telemetry, delivery events, timing records, and Platform interactions, is monitored operationally for purposes of workflow coordination, performance analytics, dispute resolution, and fraud prevention. This monitoring is a necessary operational function of the Platform and is disclosed as a condition of provider access.

B.5  Provider Information Shared with Others

BrilliantMove shares limited provider information as follows:

• With Customers: provider first name, general location (for ETA purposes), and delivery status updates;
• With Retailers: provider assignment status, arrival estimates, and pickup confirmation;
• With Payment Processors: payout information necessary to process provider compensation;
• With Legal Authorities: as required by applicable law or valid legal process.

B.6  Provider Rights

Providers have the same privacy rights as consumers described in Section A.5, subject to applicable law. Providers may also request records of their assignment history and payout data through the Platform or by contacting privacy@mybrilliantmove.com.

PART C: Retailer and Business User Privacy

This section applies to retailers, merchants, corporate account holders, and business users accessing the Platform.

C.1  Information We Collect from Retailers

BrilliantMove collects the following categories of information from retailers and business users:

• Business Identity Information: legal entity name, business address, authorized representative information, and tax identification information;
• Operational Data: inventory records, product descriptions, pickup location data, scheduling windows, and order management data;
• Customer Order Data: consumer order information submitted by retailers for Platform coordination, including delivery addresses and order contents;
• Integration Data: data transmitted through API integrations, third-party systems, point-of-sale systems, or warehouse management systems;
• Financial Data: payment processing metadata, billing records, and transaction history;
• Communications Data: operational correspondence, support records, and account management interactions.

C.2  No Use for Competitive Intelligence

BrilliantMove does not use retailer operational data, inventory data, pricing data, or business information for competitive intelligence, benchmarking against other retailers, or disclosure to retailer competitors. Retailer business data is used exclusively to operate and improve Platform services for that retailer.

C.3  Retailer Data Responsibility

Retailers who submit consumer personal information to BrilliantMove through the Platform represent and warrant that they have obtained all legally required consents and authorizations to share such information for the purposes of Platform-facilitated delivery coordination. Retailers indemnify BrilliantMove for any claims arising from the submission of consumer data without appropriate authorization.

C.4  API Integrations

Data transmitted through retailer API integrations is processed in accordance with this Privacy Policy and applicable integration agreements. BrilliantMove does not use retailer operational data for purposes unrelated to Platform services.

PART D: General Operational Data Practices

D.1  SMS and Communication Data

BrilliantMove does not sell, rent, license, or share phone numbers or SMS consent data with any third party for marketing purposes. This is an absolute and unconditional commitment.

BrilliantMove collects and processes SMS communication data, including message metadata, delivery receipts, opt-in and opt-out records, and communication timestamps. SMS communications are processed through Twilio, Inc. and other authorized telecommunications service providers pursuant to applicable data processing agreements. BrilliantMove does not retain the content of SMS messages beyond operational necessity. Opt-out records are retained indefinitely to ensure compliance with applicable law and to honor opt-out preferences.

D.2  Operational Analytics and Automation

BrilliantMove uses operational analytics and workflow optimization tools for: route optimization and delivery efficiency analysis; ETA prediction and real-time operational adjustments; fraud detection and anomaly identification; Platform performance monitoring and reliability improvement; provider matching and assignment recommendations; and service quality analysis and operational reporting.

Automated operational decisions are software-generated coordination outputs only and do not constitute employment direction, carrier operations, or exercise of control over provider conduct. Providers retain full independent judgment and are not required to follow any Platform recommendation.

D.3  No Advertising Profiling — All Users

BrilliantMove does not build advertising profiles or behavioral advertising data sets from any user’s Platform activity. No user data is sold to advertisers or data brokers.

D.4  Biometric Protection — Platform-Wide

BrilliantMove does not use facial recognition technology, biometric identification systems, or biometric data collection for any purpose on the Platform. Photographic and signature data collected through the Platform is used solely for operational delivery verification.

D.5  Data Retention

BrilliantMove retains personal and operational data for the following periods:

• Active Account Data: retained for the duration of the active account relationship and for three (3) years following account closure, unless a longer period is required by law;
• Transaction Records: retained for seven (7) years for financial, tax, and audit compliance purposes;
• Dispute and Claim Records: retained for five (5) years following resolution of any dispute or claim;
• GPS and Route Telemetry: retained for two (2) years for operational, fraud prevention, and dispute resolution purposes;
• SMS Opt-Out Records: retained indefinitely to ensure ongoing compliance with opt-out preferences;
• Fraud Investigation Records: retained for the duration necessary to complete any investigation and for applicable statutes of limitations;
• Legal Compliance Records: retained as required by applicable federal, state, and local law.

Upon expiration of applicable retention periods, data is securely deleted or anonymized.

D.6  Data Sharing

BrilliantMove may share operational information with the following categories of recipients for the purposes described in this Policy:

• Delivery Providers: customer delivery information necessary to complete assigned deliveries;
• Retailers: operational status information necessary for order and inventory management;
• Customers: provider identification, location status, and delivery confirmation data;
• Payment Processors: payment transaction data necessary to process payments and payouts;
• Telecommunications Providers: phone numbers for transactional SMS delivery (Twilio, Inc. and similar providers);
• Cloud Infrastructure Providers: data necessary for Platform hosting, storage, and computation;
• Mapping and GPS Providers: location data necessary for routing and ETA functions;
• Analytics Vendors: aggregated, de-identified operational data for platform performance analysis;
• Legal Authorities: data as required by applicable law, valid legal process, or to protect rights and safety.

BrilliantMove does not sell personal information to third parties. BrilliantMove does not share personal information with third parties for direct marketing or advertising purposes.

D.7  Security Practices

No digital system is completely secure. BrilliantMove implements industry-standard safeguards but cannot guarantee absolute security of any data. Third-party service providers maintain their own independent security practices for which BrilliantMove is not responsible.

BrilliantMove implements administrative, technical, and organizational security measures designed to protect personal and operational information from unauthorized access, disclosure, alteration, or destruction. These measures include access controls, encryption of sensitive data in transit and at rest, network security protocols, and regular security assessments.

In the event of a data breach affecting personal information, BrilliantMove will comply with applicable breach notification requirements and will notify affected individuals and regulatory authorities as required by applicable law.

D.8  Operational Necessity

Certain operational data collection — including GPS telemetry, route monitoring, delivery confirmation data, and SMS metadata — is necessary for core Platform functionality. Users consent to this collection as a condition of Platform access.

BrilliantMove’s collection of operational data, including location data, route telemetry, delivery telemetry, and platform analytics, is necessary for the core functions of the Platform: route optimization, ETA generation, fraud prevention, dispute resolution, payment facilitation, delivery confirmation, and service quality assurance. This collection is a material operational requirement and not merely incidental to Platform use. Providers and users who wish to opt out of operational telemetry collection must discontinue use of the Platform.

D.9  Cookies, Device Identifiers, and Tracking Technologies

The Platform may use cookies, session tokens, device identifiers, and operational telemetry technologies to support Platform functionality, fraud detection, performance monitoring, and user authentication. These technologies are used for operational purposes only and are not used to build advertising profiles or support third-party advertising networks.

D.10  Third-Party Services

BrilliantMove integrates with third-party services including payment processors, telecommunications providers, mapping services, cloud infrastructure vendors, and analytics platforms. Each third-party service provider processes data pursuant to its own terms and privacy policies. BrilliantMove is not responsible for the data practices of independent third-party services.

D.11  Children’s Privacy

The Platform is not directed to individuals under the age of 18. BrilliantMove does not knowingly collect personal information from minors. If BrilliantMove becomes aware that personal information of a minor has been collected, BrilliantMove will promptly delete such information.

D.12  No Sale of SMS Data — Explicit A2P Commitment

In compliance with A2P 10DLC requirements and applicable TCPA regulations: phone numbers and SMS consent data collected through the Platform are NEVER sold, rented, licensed, or transferred to any third party for marketing, commercial, or advertising purposes. This is an absolute commitment with no exceptions.

D.13  Subprocessors and Data Processing Partners

BrilliantMove may engage subprocessors and data processing partners to support Platform operations, including without limitation: cloud hosting and infrastructure providers; payment processing companies; telecommunications and SMS delivery providers; mapping, routing, and geolocation service providers; analytics and monitoring service vendors; identity verification and fraud detection services; and customer support technology platforms.

BrilliantMove requires subprocessors to maintain data protection practices consistent with this Privacy Policy and applicable law. BrilliantMove may update its subprocessor relationships from time to time. BrilliantMove will update this Policy to reflect any material changes in subprocessor practices that affect user rights. BrilliantMove remains responsible for the processing of personal data by its subprocessors to the extent required by applicable law.

D.14  No Professional or Compliance Advice

Platform outputs including route recommendations, ETA estimates, operational analytics, and workflow suggestions are informational coordination outputs only. BrilliantMove does not provide legal, compliance, privacy, regulatory, or professional advice through the Platform. Users are solely responsible for their own compliance with applicable data protection, privacy, and operational laws and should consult qualified professionals for their specific obligations.

D.15  Changes to This Policy

BrilliantMove reserves the right to update this Privacy Policy at any time. Material changes will be communicated through the Platform or via email notice. Continued use of the Platform following notice of updates constitutes acceptance of the revised Policy. The Effective Date at the top of this Policy reflects the date of the most recent revision.

Contact and Privacy Requests

For privacy questions, rights requests, or to report privacy-related concerns:

BrilliantMove, Inc. — Privacy Officer

Email: privacy@mybrilliantmove.com

Support: support@mybrilliantmove.com

Website: mybrilliantmove.com

BrilliantMove will respond to verifiable privacy requests within the timeframes required by applicable law, and in any event within forty-five (45) days of receipt, with one available extension of an additional forty-five (45) days where reasonably necessary.