Last updated September 2026
Driver Privacy Statement
Draft for review by King & Jurgens LLC. Final wording will be confirmed by counsel before launch.
Original PDFDriver Privacy Statement LABAU Concierge Drivers — what we collect, why, and what you can ask us to do
STATUS DRAFT FOR REVIEW BY KING & JURGENS LLC. State privacy law and biometric law
are jurisdiction-specific and carry statutory penalties. This statement must be reviewed against New York law and the law of any state in which a LABAU Concierge Driver resides before publication.
Last updated: ______________________
Contents 1. What this statement covers 2. What this statement does not cover 3. What personal information we collect 4. How we collect it 5. How we use it 6. Who we disclose it to, and why 7. What we do not do with your information 8. How long we keep it 9. Biometric information — collection, retention and destruction 10. How we communicate with you 11. How we secure your information 12. Your rights and how to exercise them 13. Children 14. Changes to this statement 15. Contact
1. What This Statement Covers This Driver Privacy Statement describes how LABAU Holdings, Inc. (“LABAU,” “we,” “us”) collects, uses, discloses and protects personal information relating to LABAU Concierge Drivers and prospective drivers. It applies to information collected through the LABAU Concierge Driver application, the LABAU-issued device on which that application runs, the driver onboarding process, and any other interaction with the LABAU driver program. LABAU Concierge Drivers are salaried W-2 employees of LABAU. This statement applies to you whether you are an active driver, a former driver, or an applicant who was not placed.
2. What This Statement Does Not Cover Information about LABAU members — the people to whom you deliver — is governed by the LABAU Privacy Policy, not by this statement. You will encounter limited member information in the course of a delivery. Your obligations regarding that information are set out in your W-2 employee agreement and your confidentiality agreement.
Information collected by a merchant partner on its own premises, including any camera system that merchant operates, is governed by that merchant’s own practices and not by this statement. Information collected by Starboard or Hire Society in the course of screening and placing you is governed by that agency’s own privacy practices. LABAU receives the outcome of that screening, as described in Section 4.
3. What Personal Information We Collect Not every category is collected for every driver. The categories below are the complete set.
CATEGORY
WHAT IT INCLUDES
Identity
Name, telephone number, email address, home address, date of birth, signature
Government identifiers
Driver’s license number and the information on the license, Social Security number or other taxpayer identifier, work authorization documentation
Screening outcome
The result of criminal background screening conducted by the placement agency, and of any supplementary check LABAU commissions
Vehicle
Make, model, year, registration, inspection status, and evidence of active personal auto insurance
Financial
Bank routing and account details for weekly settlement, tax information, earnings and gratuity records
Device
The identifier of the smartphone you use with the LABAU Driver app, its operating system version, application version, and device management status
Application usage
Your interactions with the Concierge Driver application — screens viewed, actions taken, timestamps, and Resource Center articles completed
Location
GPS coordinates captured at each verification moment, and continuously while you are on duty with an active delivery
Verification records
The pass or fail result of each identity verification, together with its timestamp, GPS coordinates and device identifier
Delivery evidence
Photographs you take at collection and at delivery, barcode scans, and digital signatures captured at handoff
Hours and earnings
Clock-in and clock-out times, hours worked, salary and overtime, gratuity received through payroll
Communications
Messages between you and LABAU operations, support enquiries, and incident reports you submit
Claims
Information collected when an accident, injury, loss or other claim arising from your services is reported
BIOMETRIC INFORMATION LABAU does not collect biometric identifiers. Identity verification
is performed on your device by the device manufacturer’s own biometric system. LABAU receives only the result of that verification — a pass or a fail — together with its timestamp, location and device identifier. See Section 9.
4. How We Collect It Directly from you · When you apply to the LABAU driver program · During onboarding, training and your test delivery · When you use the Concierge Driver application · When you contact operations or support, or submit an incident report · When you report a claim Automatically, through the LABAU-issued device The Concierge Driver application collects device information, application usage, location and verification records as you work. Location is collected at each verification moment and continuously while you are on duty with an active delivery. It is not collected while you are off duty. The device is enrolled in mobile device management. That system reports device status, application version and compliance state to LABAU. It does not report the content of anything on the device. From the placement agency Starboard, operating through Hire Society, screens and places LABAU Concierge Drivers. LABAU receives your identity information, the outcome of criminal background screening, and confirmation of your license and insurance status. From service providers acting for us Where LABAU commissions a supplementary background check, that provider returns the outcome to LABAU. Payment and payroll providers return settlement confirmations. What we do not collect · We do not collect information from your personal phone. Deliveries are performed on the LABAUissued device. · We do not access the camera, microphone or photo library of the LABAU device except for the delivery photographs you take within the application. · We do not collect location while you are off duty. · We do not collect information about you from social media or data brokers.
5. How We Use It · Operating the driver program — activating your account, assigning deliveries, and supporting you while you work · Verifying your identity at each of the three chain-of-custody moments · Building and maintaining the chain of custody record for each delivery · Paying you — calculating hours, applying the correct rate, settling weekly, passing through gratuity in full, and issuing your annual Form W-2 · Confirming that you meet and continue to meet the vehicle, license and insurance standards · Investigating and resolving a member dispute, a merchant dispute, an insurance claim or an incident you report · Protecting the security of the platform, the devices and the goods in transit, and detecting and preventing fraud · Meeting our legal, tax and regulatory obligations, and establishing or defending legal claims · Improving the driver application and the Resource Center
LABAU does not use automated decision-making to determine whether you are activated, deactivated, or whether a delivery is assigned to you. Delivery assignment is based on availability and proximity. A designated preferred-driver relationship is offered to you and to the member, and either may decline it.
6. Who We Disclose It To, and Why RECIPIENT
WHAT THEY RECEIVE
WHY
Payment processor
Bank details, settlement amounts, gratuity
To pay you weekly and to pass through
records
gratuity
Payroll and bookkeeping
Identity, taxpayer identifier, hours,
To run payroll and issue your Form W-2
provider
earnings
Cloud hosting provider
All platform data, encrypted at rest
To operate the platform
Device management
Device identifier and compliance status
To manage and secure the LABAU-issued
provider
device
Placement agency
Confirmation of your activation status
To administer the placement relationship
Background screening
Identity information, where a
To complete that check
provider
supplementary check is commissioned
Insurance provider
Claims information and related records,
To handle a claim involving you or a delivery
where a claim is made
you performed
RECIPIENT
WHAT THEY RECEIVE
WHY
Merchant or member
Your first name only, where necessary to
To allow a handoff to be completed
complete a delivery Law enforcement, courts
Only what is legally required
and regulators
To respond to valid legal process, or where necessary to protect safety
An acquirer
Driver records, as part of a corporate
Only in a merger, acquisition or similar
transaction
transaction, with the same protections applied
A member never receives your surname, your home address, your telephone number or your vehicle registration. A merchant receives your first name and the order reference. Contact between you and a member is masked through the application in both directions.
7. What We Do Not Do With Your Information LABAU does not sell your personal information. LABAU does not share it for cross-context behavioral advertising. LABAU runs no advertising of any kind and has no advertising platform. There is no commercial incentive to hold more information about you than the service requires, and no third party is permitted to use your information for its own purposes.
· We do not use your location to evaluate your performance, and we do not track you off duty · We do not use your verification records for anything other than the chain of custody · We do not disclose your information to a member beyond your first name · We do not permit any service provider to use your information for its own purposes
8. How Long We Keep It I NF OR M ATI ON
RETENTION
Identity, screening outcome,
For the duration of your engagement, and afterwards for the period
vehicle and insurance records
required by law and to resolve any open claim
Financial, hours, earnings and tax
For the period required by tax and employment law
records Delivery evidence and chain of
For the period required to resolve disputes, returns and insurance claims
custody records
relating to that delivery
Verification records
See Section 9
I NF OR M ATI ON
RETENTION
Location data not attached to a
Thirty days
completed delivery Application usage and device logs
Twelve months
Communications and incident
For the duration of your engagement and for the period required to resolve
reports
any open matter
When a retention period ends, records are permanently deleted. Deleted records are not archived, and no backup copy is retained beyond the routine backup cycle after which it is overwritten.
9. Biometric Information What we collect LABAU does not collect, capture, receive, store or possess a biometric identifier, template, scan or image. Identity verification is performed entirely on the LABAU-issued device by the device manufacturer’s own biometric system. The template remains in the secure hardware of that device and is not accessible to the LABAU application or to LABAU. What LABAU receives and stores is the result of each verification — a pass or a fail — together with its timestamp, GPS coordinates, the device identifier and, where verification failed, the error code returned by the device. Why Verification confirms that the person holding a member’s purchase is the driver assigned to it. It runs three times per delivery: when you go on duty, at collection from the merchant, and at delivery. Together these form the chain of custody record that protects you, the member and the merchant. It is not used for timekeeping, productivity measurement, performance evaluation or any purpose other than identity confirmation at those three moments. Consent and the alternative You are given the LABAU Biometric Data Policy and asked for written consent before activation. You may decline. If you decline, or withdraw consent later, you use the alternative method — your device passcode together with a one-time code sent to your registered number — which produces an equivalent record. Declining does not affect your engagement. Retention and destruction schedule RECORD
RETENTION
DESTRUCTION
Verification records attached to a
Retained for the period required to
Permanently deleted at the end of that
RECORD
RETENTION
DESTRUCTION
completed delivery
resolve disputes, returns and insurance
period
claims relating to that delivery Verification records not attached to
Thirty days
Permanently deleted
On the end of your engagement,
Permanently deleted no later than one
retained only where required by law or
year after the engagement ends, or
to resolve an open claim
when the initial purpose has been
a completed delivery All driver verification data
satisfied, whichever occurs first
LABAU does not sell, lease, trade or otherwise profit from biometric information or from verification data, and will not do so.
10. How We Communicate With You We may contact you by application notification, text message, email, telephone and mail. Delivery notifications while you are on duty cannot be turned off, because a driver with an active delivery needs them. Everything else can be adjusted in the application.
11. How We Secure Your Information · Encrypted in transit at TLS 1.3 and at rest at AES-256 · The LABAU-issued device is supervised, enrolled in device management, restricted to the Concierge Driver application, and can be locked and wiped remotely · No member data is stored on the device outside an active delivery · Access to driver records is restricted by role and every access is logged · Verification and delivery records are immutable — they cannot be altered after the fact · Service providers with any access are bound by written obligations no less protective than this statement No system is perfectly secure. If a breach affects your personal information, we will notify you and the relevant authorities as required by law.
12. Your Rights Wherever you live, LABAU will honour the following. Depending on your state of residence you may have additional rights. · Access — ask what personal information LABAU holds about you and receive a copy · Correct — ask us to correct anything inaccurate
· Delete — ask us to delete your personal information, subject to what we must retain by law or to resolve an open claim · Withdraw biometric consent — move to the alternative verification method at any time · Limit — ask us to limit the use of sensitive personal information to the purposes permitted by law · Confirm — ask us to confirm that a request you made has been actioned How to make a request Contact us using the details in Section 15. We will verify your identity before acting on a request, normally by asking you to confirm details we already hold. We respond within thirty days, or tell you if we need longer. An authorised agent may make a request on your behalf with written authorisation signed by you. No retaliation LABAU will not retaliate against you for exercising any right in this section. Your employment, your pay, the deliveries assigned to you and your standing with LABAU are unaffected.
13. Children The LABAU driver program is not directed at anyone under eighteen, and LABAU does not knowingly collect information from anyone under that age.
14. Changes We may update this statement. Where a change is material we will notify you at least thirty days before it takes effect, and where the change concerns biometric information or your rights we will ask you to acknowledge it in the application. The date at the top records the last revision.
15. Contact Questions, requests or complaints about this statement: LABAU Holdings, Inc. kristina@labauholdings.com labau.com New York, New York
For support relating to your account or a delivery, contact operations through the Concierge Driver application.