SCI Admin - The Premier 3PA in the Logistics Industry

DIGITAL RESOURCE PRIVACY POLICY

Effective as of 9/8/2026

Version 2026.1

Subcontracting Concepts, LLC's and its affiliated companies ("SCI," "we," "us," or "our", "Company") — that includes but is not limited to Adapt Payroll privacy policy (the "Privacy Policy") applies to the Company's Websites, its contractor and client web portals, the SCI Driver Mobile application, and any other technology owned and operated by Company to perform its services (App) (collectively, the "Digital Resources"). We have created this Privacy Policy to tell you what information we collect, how we use that information, and who we will share that information with, if at all. This Privacy Policy does not address the privacy practices of any third parties that we do not own, control, or are affiliated with.

SCI is a third-party administrator, and we serve two customer groups. The first group consists of businesses that engage SCI to provide administrative support to independent contractors ("Client"). The second group is made up of the independent contractors, themselves, that receive a payment and other services from SCI by participating and using SCI's Digital Resources (each, a "Contractor"). In some cases, a single business is both a Client and a Contractor. This Privacy Policy applies to both groups, and where a distinction matters, it is identified below.

The Client group establishes Contractor requirements and decides who to engage, retain, and pay for delivery work. SCI administers and facilitates the payments processed and makes available certain Digital Resources. SCI does not decide whether any individual is engaged, retained, or paid. This Privacy Policy describes SCI's practices only. It does not describe the privacy practices of any Client, and it does not describe the practices of any third-party vendor whose program you separately elect to join.

This Privacy Policy should be read together with our Terms of Use. We encourage you to read it in full and to use the information it contains to help you make informed decisions.

Information We Collect or Receive While operating the Company's Digital Resources, we will collect and/or receive the following information (collectively referred to as "Information").

1.1 Personal Information

We receive and collect information that identifies you personally if you choose to provide such personally identifiable information. Such Personal Information may include your name, date of birth, social security number, Employer Identification Number, bank account, and driver's license along with e-mail address, physical address, and phone number. We also receive images and copies of identity, eligibility, and qualification documents that you or a Client submit to us, that may include social security cards, driver's licenses and other government-issued identification, insurance certificates, vehicle documentation, and voided checks or other banking documentation. We do not collect any Personal Information from you unless you provide us with the Personal Information voluntarily.

1.2 Sensitive Information

Some of the Information we collect is treated as sensitive under applicable law, including your social security number, financial account and routing numbers, driver's license or other government identification number, and, where you enable it, precise geolocation from the App. We collect sensitive Information only where it is necessary to provide the services you or a Client have requested, or where required by law or by a Client's documented requirements. We do not use or disclose sensitive Information for purposes of inferring characteristics about you, and we do not sell sensitive Information.

1.3 Biometric Information

SCI does not collect, capture, use, or store biometric identifiers or biometric information, including facial geometry, fingerprints, or voiceprints. Although we receive photographs and images of identification documents, we do not perform facial recognition or facial comparison on them. If we ever introduce a process that does, we will update this Privacy Policy and adopt a written biometric retention and destruction schedule before doing so.

1.4 Information from Third Parties

We receive Information about you from Clients, from vendor program partners whose programs you have elected to join, from financial institutions, from background, motor vehicle record, and screening providers, and from insurance carriers administering programs in which you participate. We maintain application programming interfaces ("APIs") with certain of these parties. Information we receive from third parties is handled in accordance with this Privacy Policy. Section 2 describes when we disclose Information to these parties.

1.5 Payment Information

If you choose to receive a payment from SCI or Adapt Payroll or other SCI affiliate or participate in a vendor offered program that requires a fee, you will be required to provide us with your payment information, including, without limitation, bank account numbers, account details, ACH information, and similar data (collectively, "Payment Information"). Providing a bank account is not a condition of receiving payment. SCI offers methods of payment that do not require you to give us bank account information, and you may elect one of those methods instead. Such Payment Information will be collected and transmitted to our vendors pursuant to the terms and conditions of their privacy policies and terms of use.

1.6 Functional Information

Certain features and functionalities of SCI's Websites and App are based on your location, IP Address, device information and mobile network. We also collect picture, device, and network information. In order to provide these features and functionalities while you are using your mobile device, we may, with your consent, automatically collect the information from your mobile device or wireless carrier and/or certain third-party service providers (collectively, "Functional Information"). Collection of certain Functional Information from the App occurs only when the App is running on your device. You may decline to allow us to collect such Functional Information, in which case we will not be able to provide certain features or functionalities to you. You may withdraw permission for location, camera, or other device access at any time through your device settings.

1.7 Other Information

In addition to the Personal Information, Payment Information, and Functional Information, we may automatically collect or receive additional information regarding you and your use of the Company's Digital Resources; your interactions with us and our advertising; and information regarding your computer and mobile devices used to access the Company's Digital Resources (collectively, the "Other Information"). Such Other Information may include:
1. From You. Additional information about yourself that you voluntarily provide to us, such as your gender and your product and service preferences.
2. From Your Activity. IP address, which may consist of a static or dynamic IP address and will sometimes point to a specific identifiable computer or mobile device; browser type and language; referring and exit pages and URLs; date and time; and details regarding your activity on the App, such as search queries and other performance and usage data.
3. From Cookies. Information collected through cookies and similar technologies, as described in Section 4.
1.8 Support Sessions and Screen Sharing

We license third-party helpdesk software that allows a support representative to view your screen while assisting you. A support session can only begin if you initiate or affirmatively permit it, and you control what is shown and may end the session at any time. During a session, the representative may see whatever is displayed on your screen, which could include sensitive Information if you have it open. We ask that you close anything you do not wish to share before beginning a session. Support sessions are view-only, and we do not record or retain any recording of a support session.
How Information is Used and Shared.

2.1 How We Use Information

You authorize us to use the Personal Information, Information received from third parties, Payment Information, Functional Information, and the Other Information (collectively, the "Information") to:
1. provide and improve our Websites, Apps, and other Digital Resources;
2. provide our services, including onboarding administration, compliance document review and deficiency identification, payment processing, and program administration;
3. administer our promotional programs;
4. solicit your feedback;
5. inform you about our products and services;
6. maintain the security and integrity of our systems, detect and prevent fraud, and investigate suspected misuse; and
7. comply with our legal, tax, regulatory, insurance, and recordkeeping obligations.
2.2 Categories of Recipients

We disclose Information to the following categories of recipients, in each case only as necessary for the purposes described in this Privacy Policy:
1. Clients. Where you are a Contractor, we disclose your Information to the Client with whom you may or may not have performed delivery services, so that the Client can administer its own requirements and decisions.
2. Contractors and their representatives. Where you are a Client, Information about a Contractor is made available to you as necessary to administer payment, compliance, and program participation. Where you are a Contractor, we disclose your Information at your direction to obtain a payment method, insurance coverage, or participation in a program you have elected.
3. Financial institutions. Wells Fargo, for the purpose of delivering payment to you. Where you have elected a payment method that does not require bank account information, we do not disclose bank account information for that purpose.
4. Background, motor vehicle record, and screening providers, where that service is used, including for the purpose of ordering and transmitting reports.
5. Insurance carriers and program administrators, for individuals participating in their programs.
6. Vendor program partners, only after your authorization to participate in the applicable program.
7. Service providers and processors performing functions on our behalf, as described in Section 2.4.
8. Artificial intelligence providers, as described and limited in Section 3.
9. Affiliates, successors, and legal or regulatory recipients, as described in Sections 2.5 through 2.8.
2.3 Financial Information

Except as described in Section 2.2(c) and Section 3, SCI does not disclose your bank account or other financial account information to any company. We do not sell financial account information, and we do not disclose it for advertising or marketing purposes.

2.4 Vendors and Service Providers

We engage third-party companies and individuals to perform functions on our behalf. Examples may include providing technical assistance, customer service, marketing assistance, and administration of promotional programs. These other companies will have access to the Information only as necessary to perform their functions and to the extent permitted by law. We seek to bind these companies by written terms that restrict their use of the Information to the purposes for which we engaged them.

2.5 Aggregated and De-identified Information

In an ongoing effort to better understand our clients, the App, and our products and services, we may analyze certain Information in anonymized and aggregate form to operate, maintain, manage, and improve our Digital Resources and/or such products and services. This aggregate information does not identify you personally. We may share and/or license this aggregate data to our affiliates, agents, business and promotional partners, and other third parties. We may also disclose aggregated user statistics to describe SCI's Digital Resources and these products and services to current and prospective business partners and investors and to other third parties for other lawful purposes. We do not attempt to re-identify de-identified information, and we require recipients not to do so.

2.6 Affiliates

We may share some or all of your Information with any of our affiliated companies, subsidiaries, joint ventures, or other companies under common control with us.

2.7 Corporate Transactions

As we develop our businesses, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, sale of assets, dissolution, or similar event, the Information may be part of the transferred assets.

2.8 Legal Disclosures

To the extent permitted by law, we may also disclose the Information (i) when required by law, court order, or other government or law enforcement authority or regulatory agency; or (ii) whenever we believe that disclosing such Information is necessary or advisable, for example, to protect the rights, property, or safety of us or others, including you.

2.9 No Sale of Personal Information; No Advertising

SCI does not serve advertising on the Digital Resources. We do not sell your personal information for money, and we do not disclose your personal information to any party for targeted or cross-context behavioral advertising. We do use the third-party analytics services identified in Section 4. Some state privacy laws define "sale" and "sharing" broadly enough that certain analytics disclosures may fall within those definitions regardless of our intent; where that is the case, you may opt out as described in Sections 4 and 6.
Artificial Intelligence and Automated Processing.

3.1 Replacement of Prior Provision

This Section 3 replaces and supersedes the prior single-paragraph artificial intelligence provision. It describes where SCI uses artificial intelligence, what Information may be processed, and — equally important — what SCI does not do with artificial intelligence.

3.2 Where We Use Artificial Intelligence

We use artificial intelligence services, including large language models provided by reputable third-party providers, for the following purposes:
1. Onboarding and compliance document support. We use artificial intelligence to review documents submitted by you or by a Client, to assess whether those documents satisfy the requirements that a Client has imposed or the documentary prerequisites described in Section 3.4, and to identify and flag deficiencies, missing items, or illegible or expired documentation.
2. Internal operational support. We use artificial intelligence to help route, summarize, and prepare responses to correspondence we receive, and to support internal research, drafting, and analysis.
3. Internal enterprise assistant. Our personnel have access to an enterprise artificial intelligence assistant provided as part of our Microsoft 365 environment. When a member of our staff uses it, it may process business records that the staff member is already authorized to access, which can include correspondence, files, and documents containing Information. This assistant operates inside our Microsoft tenant under our enterprise agreement, and Information it processes is not used to train Microsoft's models.
4. Internal development and testing. We use artificial intelligence tools to assist our personnel in developing, testing, and maintaining our own software. Where artificial intelligence is used only to build a system, the resulting system does not itself transmit your Information to an artificial intelligence provider.
3.3 Information That May Be Processed

For the purposes described in Sections 3.2(a) through 3.2(c), the Information processed by an artificial intelligence provider may include the contents of documents you or a Client submit and the contents of correspondence. Because identity, eligibility, and payment documents are among the documents subject to review, this may include sensitive Information such as social security cards and numbers, driver's licenses and other government-issued identification, and banking documentation and account information. We transmit only the Information reasonably necessary for the review or task at hand.

3.4 No Automated Decision-Making

Artificial intelligence is used to identify and flag deficiencies for human review. It does not make decisions about you. Specifically:
1. SCI does not use artificial intelligence to decide, and does not itself decide, whether any individual is engaged, onboarded, retained, or terminated by a Client. Our Clients set their own requirements and retain full discretion over those decisions.
2. Documentary prerequisites. Separate from any Client requirement, SCI cannot process a payment unless a limited set of objective documentary prerequisites is satisfied: a completed Form W-9; a signed agreement authorizing SCI to process payments; and, for an independent contractor delivery driver, presentation of a valid driver's license. These prerequisites are objective and documentary. Verifying them does not involve any evaluation of your background, character, driving history, or qualifications, and SCI applies no discretion in applying them. Artificial intelligence may be used to flag whether a required document is present, legible, complete, or expired; SCI personnel confirm the result.
3. Output generated by artificial intelligence is reviewed by SCI personnel or provided to the applicable Client for its consideration. No adverse outcome is imposed on you by SCI based on artificial intelligence output alone.
4. We do not use artificial intelligence to profile you, to infer characteristics about you, or to make predictions about you for advertising, pricing, or eligibility purposes.
3.5 Consumer Reports and Screening

SCI does not make consumer report determinations. With respect to background checks, motor vehicle records, and similar screening, SCI acts as a pass-through: we facilitate the ordering and transmission of reports between the screening provider and the Client that requested them. SCI does not evaluate the results, does not make eligibility determinations based on them, and does not make adverse action decisions. We do not use artificial intelligence to make, influence, or recommend any such determination.

3.6 Provider Safeguards

We use established commercial artificial intelligence providers under business, enterprise, or application programming interface terms rather than consumer-grade services. Our current providers are Anthropic, Google, Microsoft, and OpenAI; this list may change, and an up-to-date list is available on request. Under the terms on which we engage these providers, Information we transmit is not used to train or improve their models. We apply data retention limitations, including zero-retention processing, where a provider makes those terms available. Information transmitted to these providers is processed in the United States.

3.7 What We Do Not Do

For the avoidance of doubt, SCI does not use artificial intelligence to perform biometric identification or facial comparison; to make or influence consumer report or adverse action determinations; to determine whether you are engaged, retained, or paid; or to make solely automated decisions that produce legal or similarly significant effects concerning you.
Cookies, Analytics, and Your Choices. We use both session cookies, which expire once you close the Website or App, and persistent cookies, which remain on your device until you delete them, along with similar technologies, to help us collect data and to enhance your experience with the Websites and App. Cookies are small text files that a website or app can use to recognize a repeat visitor.

We may use cookies and similar technologies to identify the type of mobile device or computer you use; personalize your experience on the Company's Digital Resources; analyze which Digital Resources are visited and used most frequently; and measure the effectiveness of our own communications and promotions. We do not use them to serve advertising to you.

Analytics providers. We use Google Analytics and Microsoft Clarity to understand how the Digital Resources are used. These services set cookies and collect the categories of activity information described in Section 1.7. Microsoft Clarity additionally records session activity such as page navigation, scrolling, clicks, and mouse movement, which may be replayed by us in aggregate or individually to diagnose usability and technical problems. Session recording is enabled on our portals. Text you enter into form fields is masked and is not captured; what we are able to view is limited to screen-level activity, not the contents of what you type. These providers process the information they collect in accordance with their own privacy policies and the terms under which we engage them.

Your choices. You can set your device or browser to reject cookies. You can still use the Digital Resources if you choose to disable cookies, although your ability to use some of the features may be affected. You may also opt out of Google Analytics using the browser add-on that Google makes available. We honor the Global Privacy Control signal, and you may opt out of analytics collection through the link provided on our Website. You may also submit a request under Section 6.
Data Retention. We retain Information for as long as necessary to provide the services described in this Privacy Policy and to satisfy our legal, tax, regulatory, insurance, contractual, and recordkeeping obligations. As a general matter, we retain Information relating to onboarding, contracting, compliance, and payment for the longer of the minimum period required by applicable federal and state law or eight (8) years. We may retain Information longer where it is subject to a litigation hold, discovery obligation, audit, insurance claim, or government inquiry, or where a superseding legal requirement obligates us to do so. Website and application analytics data is retained for less than four (4) years. System and application log data is retained in accordance with the period described above. We maintain an internal records retention schedule that governs these periods. When Information is no longer required for these purposes, we delete it or de-identify it.
Your Privacy Rights and Choices. SCI operates throughout the contiguous United States, the District of Columbia, and Puerto Rico. Rather than applying different standards in different jurisdictions, we extend the rights described below to all individuals in the United States and its territories, whether the law of your jurisdiction requires it. These rights are subject to the retention obligations described in Section 5 and to limitations that applicable law places on information governed by the Gramm-Leach-Bliley Act, the Fair Credit Reporting Act, and federal and state tax and transportation recordkeeping requirements. Where such a limitation prevents us from acting on a request, we will tell you.
1. Right to know and access. You may request confirmation of whether we process your personal information and request access to it.
2. Right to correct. You may request correction of inaccurate personal information.
3. Right to delete. You may request deletion of your personal information, subject to the retention obligations described in Section 5.
4. Right to portability. You may request a copy of your personal information in a portable format.
5. Right to opt out. Where applicable, you may opt out of the sale of personal information, targeted or cross-context behavioral advertising, and profiling in furtherance of decisions producing legal or similarly significant effects. See Sections 2.9 and 3.4.
6. Right to limit use of sensitive information. Where applicable, you may request that we limit our use of sensitive personal information to the purposes described in Section 1.2.
7. Right to non-discrimination. We will not deny you services, charge you a different price, or provide you a different level of service because you exercised any of these rights.
To submit a request, e-mail us at [email protected] with "Privacy Request" in the subject line, or write to us at the address in Section 13. We will take steps to verify your identity before responding, and we may decline to act on a request we cannot verify. We will respond within forty-five (45) days, and may extend that period by an additional forty-five (45) days where reasonably necessary, in which case we will notify you. An authorized agent may submit a request on your behalf with proof of authorization.

If we decline your request, you may appeal that decision by replying to our response or writing to us at the address in Section 13 with "Privacy Appeal" in the subject line. We will respond to an appeal within the period required by applicable law and, if we deny the appeal, we will provide information about how you may contact your state attorney general to submit a complaint.
Accessing and Modifying Information and Preferences. If you provided us any Information, you may access, review, and/or make changes to some of that information by contacting SCI or through its Digital Resources. Some Information may be removed as required under Federal or State law, provided no superseding law exists that requires SCI maintain that information. Requests to delete Information are handled as described in Section 6, subject to the retention obligations described in Section 5.

We may also deliver notifications to your mobile device (e.g., push notifications). You can disable these notifications by deleting the relevant service or by changing the settings on your mobile device.
Accessing Limitations. To ensure the security and integrity of our services, SCI reserves the right to limit or prohibit access to specific resources when users connect via a Virtual Private Network (VPN). Such measures may be taken to prevent unauthorized access and to maintain the quality of service for all our users.
How We Protect Your Information. We take commercially reasonable steps to protect the Information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. We maintain a written information security program that is reviewed at least annually and that provides administrative, technical, and physical safeguards for the Information. Among other measures, that program requires multi-factor authentication for access to our portals, mobile application, and internal applications; encryption of Information in transit and at rest; role-based access controls that limit internal access to personnel with a business need for it; monitoring of systems, network traffic, and electronic mail for anomalies and threats; documented procedures for identifying, containing, and responding to security incidents, with escalation to our Chief Information Officer and our President and General Counsel for evaluation of any notification obligations; due diligence and heightened review of vendors and service providers that receive Information or access payment systems; security awareness training for personnel; and prompt termination of access when an employee departs. We also maintain cyber liability insurance. Please understand, however, that no security system is impenetrable. We cannot guarantee the security of our databases or the databases of the third parties with which we may share such Information, nor can we guarantee that the Information you supply will not be intercepted while being transmitted over the Internet. In particular, e-mail sent to us may not be secure, and you should therefore take special care in deciding what information you send to us via e-mail.
Important Notices to Non-U.S. Residents. The App and its servers are operated in the United States. If you are located outside of the United States, please be aware that your Information may be transferred to, processed, maintained, and used on computers, servers, and systems located outside of your state, province, country, or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. If you are located outside the United States and choose to use the App, you acknowledge and agree to such transfer, processing, and use in the United States and elsewhere.
Children's Privacy. Our Digital Resources are intended for use by adults and are not directed to children. We do not knowingly collect personal information from anyone under the age of eighteen (18). If we learn that we have collected personal information from a child under eighteen, we will take reasonable steps to delete it. If you believe a child has provided us with personal information, please contact us using the information in Section 13.
Changes to This Privacy Policy. This Privacy Policy is effective as of the date stated at the top of this Privacy Policy. We may change this Privacy Policy from time to time. Any such changes will be posted in the SCI Website, App, or emailed. Where a change materially affects how we use or disclose Information, we will provide notice before the change takes effect and, where required by law, obtain your consent. Please be aware that, to the extent permitted by applicable law, our use of the Information is governed by the Privacy Policy in effect at the time we collect the Information. Please refer back to this Privacy Policy on a regular basis.
How to Contact Us. If you have questions about this Privacy Policy, please e-mail us at [email protected] with “Privacy Policy” in the subject line or mail us at the following address: SCI, One Broad Street Plaza, 125 Broad Street, Glens Falls, NY 12801, Attention: Privacy.

Affiliated entities covered by this Privacy Policy: Subcontracting Concepts, LLC, Adapt Payroll, and all SCI affiliated companies.

Version 2026.1