US PRIVACY POLICY

WolfX

Effective: 6 August 2026 | Version 1.0

WolfX (WolfX, we, us or our) is committed to protecting your privacy and handling your Personal Data responsibly and transparently.

This Privacy Policy explains how we collect, use, disclose, and protect your Personal Data when you access or use our website available at WolfX USA (the Website), or our platform (the Platform), which is made available through a mobile application (the App, and collectively with the Website and Platform, the Services).

By accessing or using the Services, you acknowledge that you have read and understood this Privacy Policy. Where we rely on your consent to collect or use your Personal Data, you may withdraw that consent at any time by contacting us using the details in Section 17.

OPERATIVE PROVISIONS

1. About this Privacy Policy

This Privacy Policy applies to all Personal Data we collect about you through the Services, whether collected directly from you or from third party sources.

This Privacy Policy should be read together with our Terms of Use, Acceptable Use Policy, and Cookie Policy.

We may update this Privacy Policy from time to time. Any changes will be posted on the Services with an updated effective date. Where the changes are material, we will use reasonable efforts to notify you before the changes take effect.

2. Definitions

In this Privacy Policy, the following definitions apply:

Term	Meaning
Account	means a user account created by a Student User to access and use the Platform.
Breach of Security	means unauthorized access to, or unauthorized acquisition of, computerized data that compromises the security, confidentiality, or integrity of Personal Data that we own, license, or maintain.
Carpool Feature	means the carpool matching functionality of the Platform that connects Student Users sharing university-related or other journeys, as further described in our Terms of Use and Acceptable Use Policy.
Carpool Match	means a connection or pairing between Student Users facilitated through the Carpool Feature.
Chatbot Feature	means our companion chatbot feature, called “Awaykon”.
Higher Education Institution	means a university, community college, or other higher education institution recognised by us from time to time.
Marketplace Feature	means the functionality of the Platform that allows Student Users to list, advertise, sell, buy, hire, or trade goods, services, and side ventures, as further described in our Terms of Use and Acceptable Use Policy.
Moderation Records	means the stored records of User Content reviewed by us under our content moderation program, together with associated metadata (including reviewer decisions, enforcement actions, and timestamps).
Personal Data	means any information that is linked or reasonably linkable to an identified or identifiable individual. Personal Data does not include de-identified data or publicly available information.
Podcast Content	means audio recordings, audio files, podcast metadata, transcripts, show notes, artwork, and other materials that comprise the WolfX Podcast.
Podcast Feature	means the aspect of the Platform through which Student Users can access the WolfX Podcast.
Student User	means a person who is at least 18 years of age and a current or recently enrolled student at a Higher Education Institution, who has registered for an Account.
Study Tool Feature	means the aspect of the Platform through which Student Users can use an AI-powered tool to assist with their studies.
Subscription Fee	means a recurring fee for access to the Platform, which varies depending on the Subscription Tier.
Subscription Period	means each monthly period, with the first monthly period beginning on the date you first purchase a Subscription Tier.
Subscription Tier	means the type of subscription to the Platform, designated as either gold, silver, or platinum, each of which comes with different levels of access to the Platform.
Transaction	means a Marketplace Transaction, a Carpool Match arrangement, or any other transaction made between Student Users or to us.

3. Interpretation

In this Privacy Policy, unless the context otherwise requires:

headings are for convenience only and do not affect interpretation;
the singular includes the plural and vice versa;
a reference to a person includes a corporation, partnership, joint venture, association, government body, or other entity;
a reference to a statute, regulation, or other law includes all amendments, consolidations, and replacements;
a reference to writing includes email; and
where a word or expression is given a particular meaning, other parts of speech and grammatical forms of that word or expression have a corresponding meaning.

4. Information we collect

The types of Personal Data we collect about you depend on how you interact with the Services.

Information you provide to us includes:

account registration information, including your name, email address (which may include your Higher Education Institution email address), phone number, username, password, and date of birth (for age verification);
student verification information, including your Higher Education Institution, course of study, year of study, student identification number, and the outcome of any verification check we (or a third party student verification provider engaged by us) conduct;
identity verification information, including any government-issued identification you provide and, if you offer Carpool Matches, your driver's license and vehicle registration details;
payment and billing information, processed through our third party payment provider and (where you purchase a Subscription Tier) through the Apple App Store or the Google Play Store;
profile information, including any profile picture, display name, biographical details, course or interest areas, and preferences you choose to provide;
User Content that you create, list, post, upload, or share through the Services, including Marketplace and Student Venture listings, messages to other Student Users, inputs and outputs from the Chatbot Feature, content generated through the Study Tool Feature, and posts within community features;
Carpool data, including your pick-up and drop-off locations, journey times, routes, vehicle details (if you offer Carpool Matches), and any cost-sharing or rating information you submit;
communications you send to us, including support requests, feedback, and correspondence; and
any other information you voluntarily provide to us through the Services.

Information we collect automatically includes:

device and browser information, including your IP address, device type, operating system, browser type, and unique device or advertising identifiers;
usage data, including pages and features accessed, time spent on the Services, Carpool Matches submitted or accepted, listings viewed or transacted, Podcast Content played, referring URLs, search terms, and clickstream data;
approximate location data derived from your IP address or, where you have provided consent through the in-App permissions, precise location data from your device (for example, to support pick-up and drop-off coordination through the Carpool Feature); and
cookie and tracking technology data, as described in our Cookie Policy.

Information we receive from third parties: we may receive Personal Data about you from third party sources, including identity and student status verification providers, payment processors (including the Apple App Store and the Google Play Store), mapping providers, analytics providers, advertising networks, and social login providers (where you choose to sign in through a third party account).

Sensitive Data: we do not generally seek to collect Sensitive Data about you. You should not submit Sensitive Data to the Services other than where reasonably necessary for an arrangement (for example, an allergy or medical condition disclosed for the purpose of a Carpool Match). Where we do collect Sensitive Data, we will only do so with your consent or where the collection is reasonably necessary for your use of the Services.

5. How we collect your information

We collect Personal Data:

directly from you, when you register for an Account, build a profile, submit User Content, or otherwise use various features of the Services;
automatically, through cookies, analytics tools, and similar technologies when you access or interact with the Services; and
from third parties, as described in Section 4 above.

Where it is reasonable and practicable to do so, we will collect Personal Data directly from you. We will not collect Personal Data by unlawful or unfair means.

6. How we use your information

We use your Personal Data for the primary purposes for which it was collected. These include:

providing, operating, maintaining, and improving the Services and the features made available through it;
creating and managing your Account
Processing your Subscription Tier orders and other Transactions;
verifying your eligibility for the Platform;
coordinating arrangements between Student Users (e.g., Carpool Matches), including by displaying relevant Personal Data to a Student User to the extent reasonably necessary to perform the arrangement;
communicating with you, including sending service-related notices, in-App and email notifications about arrangements, responding to your inquiries, and providing customer support;
sending you marketing or promotional communications where you have consented or where we are otherwise permitted to do so by law (subject to Section 7);
conducting analytics, research, and product development to understand and improve user experience and the performance of the Services;
detecting, preventing, and responding to fraud, security incidents, harmful or unlawful content, breaches of our Acceptable Use Policy, and breaches of our other terms; and
complying with our legal obligations (including our Breach of Security notification obligations), enforcing our terms, and protecting our rights and the rights of others.

We will not use your Personal Data for a purpose materially different from the purpose for which it was collected, unless we have obtained your consent or are otherwise permitted or required by law.

7. Direct marketing

We may use your Personal Data (including your name and contact details) to send you direct marketing communications about our products, services, promotions, competitions, or events where you have consented or where we are otherwise permitted to do so under applicable law.

You may opt out of receiving direct marketing communications from us at any time by:

using the unsubscribe link included in each marketing email;
updating your communication preferences in your Account settings; or
contacting us using the details in Section 17.

If you opt out of direct marketing communications, we will continue to send you service-related communications that are necessary for us to provide the Services.

8. Content moderation

To protect the safety and integrity of the Services and our users, we operate a content moderation program that involves the following:

automated classification and filtering of User Content to detect potential breaches of our Acceptable Use Policy;
human review of content that has been flagged by our automated systems or reported by another user, for the purpose of confirming the classification and determining the appropriate response;
the recording and retention of Moderation Records, including the content reviewed, the reviewer's decision, and any enforcement action taken; and
the use of Moderation Records to enforce our Acceptable Use Policy, to respond to reports or complaints, and to provide evidence in connection with disputes, investigations, or legal proceedings.

9. Disclosure of your information

We may disclose your Personal Data to the following categories of recipients:

Other Student Users: to the extent reasonably necessary to facilitate arrangements between Student Users. For example, a Student User offering a Carpool Match may see the first name, profile photo, and pick-up location of a Student User who accepts that match. As another example, if a Student User sends a direct message to another Student User, the recipient Student User will see any Personal Data included within the message;
Service providers: third party providers who perform services on our behalf, including hosting and cloud infrastructure providers, payment processors (including Apple App Store and Google Play Store billing), artificial intelligence model providers, identity and student status verification providers, mapping and navigation providers, customer support tools, email and SMS delivery providers, content moderation services, marketing partners, and analytics providers;
Group entities: other entities within the Purple TIC Enterprises group, where necessary to provide and support the Services;
Professional advisors: our lawyers, accountants, auditors, and insurers, where necessary for the provision of their services;
Law enforcement and regulators: government authorities, law enforcement agencies, courts, where required or authorized by law, or to protect our legal rights and the rights of others; and
Business transfers: a potential buyer, transferee, investor, or merger partner in the event of a sale, merger, restructure, or other transfer of all or part of our business or assets.

Before disclosing your Personal Data to a third party, we take reasonable steps to ensure that the third party is contractually obliged to handle your Personal Data in accordance with applicable law and this Privacy Policy.

We do not sell your Personal Data.

10. Overseas disclosure

We are based in the United States. Some of our service providers (including cloud infrastructure, payment processors, and podcast distribution providers) may be located outside the United States. Where we disclose your Personal Data to a recipient located outside the United States, we take reasonable steps to ensure that the recipient provides a level of protection for your Personal Data that is consistent with this Privacy Policy and applicable law.

11. Data retention

We retain your Personal Data only for as long as is reasonably necessary to fulfill the purposes for which it was collected, including to satisfy any legal, regulatory, accounting, or reporting requirements, or to resolve disputes and enforce our agreements.

To determine the appropriate retention period, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure, the purposes for which we process the information, whether we can achieve those purposes through other means, and applicable legal requirements.

When your Personal Data is no longer required, we will take reasonable steps to destroy or de-identify it in accordance with our information handling procedures. Where de-identification is used, the de-identified information may be retained for analytical and research purposes (including to improve the Services).

We may retain your Personal Data (including User Content and Moderation Records) for longer than we would otherwise need to where you have consented to the extended retention, or where we are required or permitted to do so by law, including to respond to disputes, complaints, investigations, or legal proceedings. Where we defer action on a deletion or correction request on this basis, we will notify you of the reason and the expected timeframe for completion.

12. Data security

We take reasonable steps to protect your Personal Data from misuse, interference, loss, and unauthorized access, modification, or disclosure. These steps include:

encryption of Personal Data in transit and, where appropriate, at rest;
access controls that limit access to Personal Data to authorized personnel on a need-to-know basis;
regular security assessments and testing of our systems and processes;
staff training on privacy and data handling obligations; and
incident response procedures for investigating and responding to actual or suspected Breaches of Security.

While we take reasonable steps to protect your Personal Data, no method of transmission over the internet or method of electronic storage is completely secure. We cannot guarantee the absolute security of your Personal Data.

13. Your rights

You have the right to:

Access: confirm whether we are processing your Personal Data and access such Personal Data;
Correction: correct inaccuracies in your Personal Data;
Deletion: request deletion of your Personal Data;
Portability: obtain a copy of your Personal Data that we process, in a portable and, to the extent technically feasible, readily usable format, where the processing is carried out by automated means; and
Opt-out: opt out of the processing of your Personal Data for purposes of (i) targeted advertising, (ii) the sale of Personal Data, or (iii) profiling in furtherance of solely automated decisions that produce legal or similarly significant effects concerning you. We do not sell your Personal Data, but we may use your Personal Data for the purpose of targeted advertising. You can opt out of our use of your Personal Data for targeted advertising by emailing us at support@wolfxusa.com. In addition, we recognize GPC signals.
Complaint: make a complaint to us if you believe we have breached applicable law or mishandled your Personal Data.

To make a request to exercise any of these rights, please contact us using the details in Section 17. We may require you to verify your identity before actioning your request.

We will respond to your request within a reasonable period and, in any event, within 30 days of receiving the request. We will not charge you for making a request, but we may charge a reasonable fee for providing access if the request requires substantial effort. We will explain the basis of any charge before responding.

There are circumstances in which we may decline a request (for example, where we cannot verify your identity, or where an exception under applicable law applies). If we decline a request, we will explain our reasons and how you can appeal. You may appeal our decision by contacting us using the details in Section 17. We will respond to your appeal within 60 days of receipt, explaining any action taken or not taken and the reasons for our decision.

14. Cookies and tracking technologies

We use cookies and similar tracking technologies on the Services. For detailed information about the cookies we use, the purposes for which we use them, and how you can manage your cookie preferences, please refer to our Cookie Policy, available at our Cookie Policy.

15. Third party links

The Services may contain links to third party websites, services, or applications that are not operated or controlled by us (including payment processors, mapping providers, Higher Education Institution single sign-on providers, and identity verification providers). This Privacy Policy does not apply to those third party services, and we are not responsible for their privacy practices.

We encourage you to review the privacy policies of any third party services before providing your Personal Data to them.

16. Children's privacy

The Services are not directed at, and we do not knowingly collect Personal Data from, children under the age of 18. You must be at least 18 years of age and a Student User to create an Account, transact through the Platform, or otherwise use the Services.

If we become aware that we have collected Personal Information from a person under 18, we will take reasonable steps to delete that information as soon as practicable. If you believe that we may have collected information from a person under 18, please contact us immediately using the details in Section 17.

17. Contact us and complaints

For support and enquiries, contact us at support@wolfxusa.com.

We will aim to resolve your complaint within 30 days of receipt. If we need more time, we will let you know the reason for the delay and the expected timeframe for resolution.

18. Changes to this Privacy Policy

We reserve the right to amend this Privacy Policy at any time. Any changes will be effective when we post the revised Privacy Policy on the Services with an updated effective date.

Where the changes are material, we will use reasonable efforts to notify you by email (where we have your email address) or by posting a prominent notice on the Services before the changes take effect.