INDEPENDENT CONTRACTOR PRIVACY POLICY

Scrub Art Cleaning Inc.
Effective Date: September 15, 2025
Last Updated: August 25, 2025

PRIVACY COMMITMENT

Scrub Art Cleaning Inc. (“Company,” “we,” “us,” “our”) is committed to protecting the privacy
and personal information of our independent contractors (“Contractor,” “Cleaner,” “you,”
“your”). This Privacy Policy explains how we collect, use, disclose, and safeguard your
information when you use our mobile application and web platform (“App”).

By using our platform, you consent to the practices described in this Privacy Policy.

1. INFORMATION WE COLLECT

1.1 Registration & Profile Information

• Personal Details: Full legal name, date of birth, Social Security/Social Insurance Number
• Contact Information: Email address, phone number, home address, emergency contact
• Professional Information: Business name, business license numbers, certifications
• Banking Information: Account details for payment processing, tax forms (W-9/T4)

1.2 Verification & Background Check Information

• Identity Verification: Government-issued photo ID, passport, driver’s license
• Background Checks: Criminal history, employment verification, reference checks
• Insurance Documentation: Liability insurance, bonding certificates, policy numbers

1.3 Work-Related Information

• Service Areas: Geographic locations where you provide services
• Availability: Schedule preferences, working hours, availability calendar
• Service History: Completed jobs, client ratings, earnings records, performance metrics
• Equipment & Supplies: Cleaning equipment inventory, supply preferences

1.4 Financial Information

• Payment Details: Bank account information, payment preferences
• Earnings Records: Job payments, platform fees, tax withholdings, 1099/T4A information

1.5 Location & Tracking Information

• Real-time Location: Online Map coordinates during active service periods for safety and verification
• Service Locations: Client property addresses, travel routes, check-in/check-out times
• Location History: Previous job locations for performance analysis and route optimization

1.6 Device & Technical Information

• Device Data: Smartphone/tablet model, operating system, app version, device ID
• Usage Analytics: App features used, session duration, performance metrics
• Technical Logs: Error reports, crash logs, connectivity issues

1.7 Communication Records

• Platform Messages: Communications with clients and support staff
• Phone Records: Recorded calls with customer service and clients (with notice)
• Incident Reports: Safety reports, damage claims, dispute documentation

2. HOW WE USE YOUR INFORMATION

2.1 Contractor Verification & Onboarding

• Identity verification: Confirm your identity and eligibility to work
• Background screening: Ensure safety and reliability for client protection
• Credential Verification: Validate professional licenses and insurance coverage
• Platform Access: Create and maintain your contractor profile

2.2 Work Assignment & Matching

• Job Matching: Connect you with appropriate client service requests
• Location Services: Match you with clients in your service areas
• Availability Tracking: Schedule jobs based on your availability preferences
• Performance Optimization: Improve job assignments based on your skills and
  ratings

2.1 Contractor Verification & Onboarding

• Identity verification: Confirm your identity and eligibility to work
• Background screening: Ensure safety and reliability for client protection
• Credential Verification: Validate professional licenses and insurance coverage
• Platform Access: Create and maintain your contractor profile

2.2 Work Assignment & Matching

• Job Matching: Connect you with appropriate client service requests
• Location Services: Match you with clients in your service areas
• Availability Tracking: Schedule jobs based on your availability preferences
• Performance Optimization: Improve job assignments based on your skills and ratings

2.3 Payment & Financial Management

• Payment Processing: Calculate earnings, deduct fees, process payments
• Tax Reporting: Generate tax forms (1099/T4A), track business income
• Expense Management: Track business-related expenses and deductions
• Financial Analytics: Provide earnings reports and financial insights

2.4 Safety & Quality Assurance

• Location Tracking: Monitor your safety during service periods
• Performance Monitoring: Track service quality, punctuality, and client satisfaction
• Incident Management: Document and investigate safety incidents or disputes
• Insurance Claims: Facilitate insurance claims for damages or injuries

2.5 Communication & Support

• Job Notifications: Send booking requests and job updates
• Platform Updates: Communicate policy changes and new features
• Customer Support: Provide technical assistance and resolve issues
• Training Materials: Deliver educational content and best practices

2.6 Business Operations & Compliance

• Legal Compliance: Meet regulatory requirements for independent contractor relationships
• Platform Improvement: Analyze usage patterns to enhance app functionality
• Market Research: Understand contractor needs and service demands
• Fraud Prevention: Detect and prevent fraudulent activities

3. INFORMATION SHARING & DISCLOSURE

3.1 Client Information Sharing

We share necessary information with clients to facilitate service delivery:

• Professional Profile: Your name, photo, ratings, and service specialties
• Contact Information: Phone number for direct communication during service
• Location Updates: Real-time location during active service periods
• Service History: Relevant experience and client testimonials
• We do not share: Personal address, financial information, or sensitive personal details

We do not share: Personal address, financial information, or sensitive personal details

3.2 Background Check Providers

• Criminal Background Checks: Identity verification and criminal history screening
• Employment Verification: Previous work history and professional references
• Insurance Verification: Confirming coverage and policy validity
• Ongoing Monitoring: Periodic re-screening as required

3.3 Financial Service Providers

• Payment Processors: Stripe, or similar services for payment processing
• Banking Partners: For direct deposit and financial transactions
• Tax Preparation Services: For 1099/T4A generation and tax compliance
• Accounting Services: For financial reporting and business analytics

3.4 Technology Service Providers

• Cloud Storage: Google Cloud, or similar hosting providers
• Analytics Platforms: Google Analytics, Firebase for app performance monitoring
• Communication Tools: SMS/email providers for notifications and updates
• Security Services: Fraud detection and cybersecurity monitoring

3.5 Legal & Regulatory Disclosures

• Government Agencies: Tax authorities, labor departments, regulatory bodies
• Law Enforcement: When required by law or legal process
• Legal Proceedings: Court orders, subpoenas, or legal investigations
• Insurance Companies: For claims processing and coverage verification
• Emergency Services: During safety incidents or medical emergencies

3.6 Business Transfers

• Your information may be transferred to the new entity with equivalent privacy protections in the event of merger, acquisition, or asset sale

3.7 What We DO NOT Share

• We do not sell your personal information to third parties
• We do not share your information for others’ direct marketing without consent
• We do not disclose sensitive financial information unnecessarily
• We do not share personal information with unauthorized parties

4. DATA RETENTION

4.1 Active Contractor Records

• Profile Information: Retained while account is active plus 7 years
• Financial Records: Retained for 7 years for tax and accounting purposes
• Background Checks: Retained for 7 years or as required by law
• Insurance Records: Retained for policy period plus 7 years

4.2 Inactive Contractor Records

• Account Information: Retained for 3 years after account deactivation
• Work History: Retained for 5 years for reference and dispute resolution
• Communication Records: Retained for 3 years for quality assurance
• Performance Data: Anonymized and retained for business analytics

4.3 Legal & Compliance Records

• Tax Records: Retained for 7 years as required by law
• Background Checks: Retained as required by regulatory authorities
• Insurance Claims: Retained for statutory limitation periods
• Incident Reports: Retained for 7 years for legal protection

4.4 Secure Deletion Process

• Information is permanently deleted from active systems
• Backup systems are purged within 90 days
• Physical documents are securely destroyed
• Data is de-identified for statistical analysis only

5. YOUR PRIVACY RIGHTS

5.1 Access Rights

You have the right to:

• View Your Data: Access all personal information we hold about you
• Data Portability: Receive your data in machine-readable format
• Processing Information: Understand how your data is being used
• Third-Party Sharing: Know who we share your information with

5.2 Correction & Update Rights

You may:

• Update Profile: Modify your contact and professional information
• Correct Errors: Request correction of inaccurate information
• Add Information: Provide additional credentials or certifications
• Update Preferences: Change communication and privacy settings

5.3 Deletion & Restriction Rights

You may request:

• Account Deletion: Permanent removal of your contractor account
• Data Deletion: Removal of specific categories of information (subject to legal requirements)
• Processing Restriction: Limit how we use certain information
• Communication Opt-out: Stop non-essential communications

5.4 Objection Rights

You may object to:

• Marketing Communications: Opt out of promotional materials
• Certain Data Processing: Object to specific uses of your information
• Automated Decision-Making: Request human review of algorithmic decisions
• Data Sharing: Limit sharing with certain third parties (where legally permissible)

6. DATA SECURITY

6.1 Technical Security Measures

• Advanced Encryption: Encryption for data at rest and in transit. While we take strong precautions, no system is 100% secure
• Access Controls: Multi-factor authentication and role-based permissions
• Regular Security Updates: Continuous system patches and security improvements
• Intrusion Detection: 24/7 monitoring for security threats and breaches

6.2 Administrative Security Measures

• Employee Training: Comprehensive privacy and security training for all staff
• Background Checks: Security clearance for employees accessing contractor data
• Data Minimization: Collect and retain only necessary information
• Regular Audits: Annual third-party security and compliance assessments
• Incident Response Plan: Documented procedures for security breach response

6.3 Physical Security Measures

• Secure Facilities: Physical security for data centers and offices
• Access Logging: All facility and system access logged and monitored
• Secure Disposal: Certified destruction of hardware containing data
• Environmental Controls: Climate control and disaster protection for servers

6.4 Mobile App Security

• App Security: Code obfuscation and anti-tampering protections
• Secure Communication: Certificate pinning for API communications
• Local Storage: Minimal sensitive data stored on devices
• Session Management: Automatic logout and session timeout protections

7. BACKGROUND CHECKS & VERIFICATION

7.1 Background Check Process

• Criminal History: Federal, state/provincial, and local criminal records
• Identity Verification: Government ID verification and fraud detection
• Employment History: Previous employer verification and professional references
• Education Verification: Relevant certifications and training validation
• Motor Vehicle Records: Driving history for contractors using vehicles

7.2 Background Check Partners

• Fair Credit Reporting Act (FCRA): Compliance in the United States
• Personal Information Protection and Electronic Documents Act (PIPEDA): Compliance in Canada
• Local Privacy & Employment Laws: Compliance in all operating jurisdictions

7.3 Your Rights Regarding Background Checks

• Pre-Screening Notice: Clear notification before conducting background checks
• Consent Requirements: Explicit consent for each type of screening
• Results Disclosure: Right to receive copies of background check reports
• Dispute Process: Procedures to dispute inaccurate information
• Adverse Action Notice: Notification if employment is affected by background check results

8. FINANCIAL INFORMATION & TAX COMPLIANCE

8.1 Financial Data Protection

• Banking Security: Bank-level encryption for financial information
• PCI DSS Compliance: Payment card industry security standards
• Segregated Storage: Financial data stored separately with enhanced security
• Limited Access: Restricted access to financial information on a need-to-know basis

8.2 Tax Reporting & Compliance

• IRS/CRA Compliance: Full compliance with tax reporting requirements
• Form Generation: Automated 1099/T4A creation and distribution
• Record Keeping: Comprehensive earning and expense tracking
• Privacy Protection: Tax information shared only with authorized parties

9. LOCATION TRACKING & SAFETY

9.1 Location Data Collection

We collect location information for:

• Safety Monitoring: Ensure contractor safety during service calls
• Service Verification: Confirm service completion and location accuracy
• Emergency Response: Provide assistance during emergencies or incidents
• Route Optimization: Suggest efficient travel routes between jobs

9.2 Location Data Protection

• Encrypted Storage: All location data encrypted with military-grade security
• Limited Retention: Location history deleted after 90 days unless required for incidents
• Access Controls: Restricted access to location data for authorized personnel only
• Client Privacy: Location sharing with clients limited to active service periods

9.3 Location Privacy Controls

You may:

• Control Sharing: Enable/disable location sharing through app settings
• View History: Access your location data and sharing history
• Delete Data: Request deletion of location history (subject to legal requirements)
• Emergency Override: Automatic location sharing during emergency situations

10. MARKETING & COMMUNICATIONS

10.1 Communication Types

We may communicate with you through the following:

• Essential Communications: Job assignments, payment notifications, safety alerts
• Business Updates: Policy changes, app updates, important announcements
• Marketing Communications: Promotional offers, referral programs, industry news
• Educational Content: Training materials, best practices, skill development

10.2 Communication Preferences

You can control:

• Email Frequency: Daily, weekly, or monthly communication preferences
• SMS Notifications: Opt in/out of text message alerts
• Push Notifications: Control mobile app notification settings
• Marketing Opt-out: Unsubscribe from promotional communications anytime

11. REGIONAL PRIVACY LAW COMPLIANCE

11.1 Canadian Privacy Laws

We comply with the following:

• PIPEDA: Personal Information Protection and Electronic Documents Act
• Employment Standards: Provincial employment and contractor protection laws

11.2 US Privacy Laws

We comply with the following:

• Federal Regulations: FTC privacy requirements and industry-specific regulations

12. INCIDENT REPORTING & DATA BREACHES

12.1 Incident Response Procedures

In the event of a data breach or security incident, we follow these procedures:

• Immediate Assessment: Rapid evaluation of scope and impact
• Containment: Immediate steps to prevent further data exposure
• Investigation: Thorough investigation to determine cause and extent
• Notification: Prompt notification to affected contractors and authorities
• Remediation: Implementation of measures to prevent future incidents

12.2 Notification Timelines

• Regulatory Notification: Within 72 hours to data protection authorities (where required)
• Individual Notification: Within a reasonable timeframe directly to affected contractors
• Public Disclosure: If required by law or if risk to public safety exists
• Follow-up Communications: Regular updates throughout investigation and remediation

13. PRIVACY POLICY UPDATES

13.1 Change Notification Process

We will notify you of privacy policy changes through:

• Email Notification: Direct email to your registered address
• App Notifications: In-app alerts about policy updates
• Website Posting: Updated policy posted on our website

13.2 Consent for Changes

• Continued Use: Ongoing platform use constitutes acceptance of updated terms
• Opt-out Option: Right to discontinue service if you disagree with changes
• Granular Consent: Separate consent for new data processing activities
• Withdrawal Rights: Right to withdraw consent for optional data uses

14. CONTACT INFORMATION & COMPLAINTS

14.1 Privacy Contact Information

Primary Privacy Contact:
Email: info@scrubartcleaning.com
Phone: 226-777-7117

Data Protection Officer:
Email: info@scrubartcleaning.com
Phone: 226-777-7117

14.2 Response Timeframes

• General Privacy Inquiries: 5 business days
• Data Access Requests: 30 days (may extend to 60 days for complex requests)
• Data Correction Requests: 10 business days
• Privacy Complaints: 10 business days for initial response, full investigation within 30 days

14.3 Account Deletion Process

1. Email Request: Send request to contractor-privacy@scrubartcleaning.com
2. Identity Verification: Confirm your identity through secure verification process
3. Final Payment: Ensure all outstanding payments are processed
4. Data Retention Notice: Understand which data will be retained for legal compliance
5. Confirmation: Receive confirmation of account deletion within 30 days

15. DATA SUBJECT RIGHTS SUMMARY

15.1 Your Rights at a Glance

• Right to Know: What personal information we collect and how it’s used
• Right to Access: Request copies of your personal information
• Right to Correct: Update or correct inaccurate information
• Right to Delete: Request deletion of your personal information
• Right to Restrict: Limit how we process your information
• Right to Object: Object to certain data processing activities
• Right to Withdraw Consent: Revoke consent for optional data processing

15.2 Exercising Your Rights

1. Contact Us: Use the contact information provided above
2. Verify Identity: We may require identity verification for security
3. Specify Request: Clearly describe which right you want to exercise
4. Response Timeline: We will respond within legally required timeframes
5. Follow-up: We will provide status updates for complex requests

This Privacy Policy is effective as of the date listed above and governs your use of our
contractor platform. By using our services, you acknowledge that you have read,
understood, and agree to this Privacy Policy.

CONTRACTOR ACKNOWLEDGMENT

By accepting this Privacy Policy, you confirm that:

• You have read and understood all sections of this Privacy Policy
• You consent to the collection, use, and disclosure of your personal information as described
• You understand your rights and how to exercise them
• You acknowledge the international nature of data processing for platform services
• You agree to promptly update your information to maintain accuracy