Tullo Privacy Policy

Effective Date: October 22, 2025

Introduction

Tullo (“Tullo,” “we,” “our,” or “us”) provides premium rideshare services in Houston, Texas, with plans to expand throughout the United States. This Privacy Policy explains how we collect, use, disclose, and safeguard personal information relating to our users. By accessing or using any Tullo website, mobile app, or related service (“Services”), you agree to the terms of this Policy.

Scope and Segmentation

This Policy applies to both Riders and Drivers on the Tullo platform. Where relevant, differences are clearly indicated for each group.

Information We Collect

1. Information Provided Directly

• Account/Profile: Name, email, phone, address, user photo, user ID, password (encrypted)
• Payment Details: Billing information and transaction records (processed securely by third-party providers)
• Ride Data: Pickup and drop-off locations, trip details and history, preferences, ride feedback, and ratings
• Driver Verification (Drivers Only): Driver’s license, vehicle registration, insurance, background check, government identification
• Communications: Service requests, support tickets, in-app messages, and complaints

2. Information Collected Automatically

• Device/Usage Data: IP address, device identifications, app/browser type and version, OS, referring URLs, session times, and usage analytics
• Location Data: Real-time and historical GPS, Wi-Fi, or cell tower signals
• Cookies/Tracking Technologies: See Cookies section below
• Analytics: Usage and traffic data from tools such as Google Analytics and Facebook Pixel

3. Information from Third Parties

• Social logins (e.g., Facebook, Google)
• Payment processors
• Background check providers
• Marketing/advertising partners (when applicable)

How We Use Information

• Operate, administer, and improve Tullo’s platform and Services
• Match riders and drivers based on availability, location, and ratings
• Authenticate identities and protect against fraud or abuse
• Process payments and resolve billing issues
• Communicate updates, support, and notifications
• Conduct analytics, personalize user experiences, and market services (with required consent)
• Screen driver eligibility (applicable to drivers only)
• Comply with legal, regulatory, and tax requirements

Automated Decision-Making

Tullo automates certain processes to match rides based on availability and ratings and to detect potentially fraudulent or prohibited activity. No high-impact decisions, such as driver deactivation, are made solely by automated systems—human review is provided where necessary.

Disclosure and Sharing

• Service Providers: Payment processors, verification companies, analytics, hosting, and support vendors
• Matched Counterparties: Rider name/profile shared with drivers and vice versa for trip logistics
• Legal or Regulatory: As required by law, subpoena, or mandate
• Business Transfers: In a merger, acquisition, or restructure (with advance notice as required)
• Advertising/Analytics: Aggregated or pseudonymized data for analytics, website optimization, and retargeting—never sold for monetary value or shared without your consent
• With Consent: For new services or features, with your explicit consent

State and International Coverage

This policy is designed for Texas residents but anticipates requirements in California, Virginia, Colorado, Connecticut, and other U.S. states. Individuals in those states have additional rights described below.

California, Virginia, Colorado, Connecticut Residents

• Request access, correction, or deletion of your personal information
• Opt out of the “sale” or “sharing” of your information for targeted advertising (see instructions below)
• Request information about data processing (“right to know”)
• Limit use of sensitive personal information (CA only)

Cookies and Tracking Technologies

Tullo uses cookies and similar tracking technologies to:

• Authenticate users and maintain secure sessions
• Analyze traffic and improve Services (e.g., via Google Analytics and Facebook Pixel)
• Support advertising & retargeting as permitted by law
• Save preferences and settings
• Identify/resolve bugs or technical issues

Third-party cookies may be set by analytics or advertising partners. You can manage cookies through your browser/device settings; disabling cookies may affect site functionality.

Tullo may provide a separate or updated Cookie Policy as the use of new technologies is expanded.

User Rights and Opt-Out Process

To exercise privacy rights, email us at privacy@tullo.com

• Request access, correction, or deletion of your information
• Opt out of sharing for advertising—just email us and we will honor your request
• No data is sold for monetary value

Tullo responds to verified requests within 30 days and will not discriminate against users exercising their privacy rights.

Security

Tullo uses commercially reasonable safeguards including encryption, secure access controls, staff training, and monitoring. Driver verification documents are handled and stored with extra care and limited access. Despite these measures, no system can guarantee absolute security—please report concerns directly to us.

Data Retention

Personal information is kept only as long as necessary to provide services, meet legal and regulatory requirements, defend against claims, and resolve disputes. Account and trip records may be retained up to seven years unless a deletion request is verified and permitted.

Children's Privacy

Tullo does not allow users under 18 or knowingly collect information from minors. If such data is found, it will be deleted promptly.

International Data Transfers

Your data may be stored and processed in the United States or other jurisdictions. Tullo implements appropriate safeguards for international transfers where required by law.

Changes to this Policy

Tullo may update this Privacy Policy at any time. Material changes will be communicated here and, if required, by direct notice. Please review this page regularly for updates.

Contact Information

Tullo Privacy Office
3724 Cypress Creek Parkway, Suite 237
Houston, TX 77068
Email: privacy@tullo.com

Sections for Riders and Drivers

All major sections apply to both rider and driver accounts. Any specific differences, such as documents required for driver verification, are noted in the relevant section.