Private Policy– SmartWash PRO, LLC

December 15th, 2025

11.1 Scope

This Privacy Policy applies to all services, interactions, and operations conducted by SmartWash PRO, LLC (the “Provider”), across its three established business verticals:

1. SmartWash Pro Elite: Services for aviation, RVs, marine vessels (boats), luxury vehicles, motorcycles, and other high-value transportation assets.

2. SmartWash Pro Commercial: Services for commercial buildings, retail storefronts, gas stations, and other fixed structures or facilities.

3. SmartWash Pro Events: On-site services at trade shows, auto shows, boat shows, and other public or private events.

This policy governs the processing of all personal, corporate, and technical data collected through:

· Our website (smartwashpro.com) and online service requests.

· Written contracts, Service Quotations, and Work Orders.

· The physical performance of services at client locations, hangars, marinas, events, or commercial sites.

The data covered includes, but is not limited to:

· Client and Business Information: Names, contact details, company data, and payment information.

· Asset Information: Identifiers (e.g., aircraft tail number, vessel HIN, vehicle VIN), specifications, and location data.

· Service Documentation: Pre- and post-service inspection reports, checklists, work orders, and condition assessments conducted per our Standard Operating Procedures (SOP).

· Audiovisual Records: Photographs, video recordings, and footage from body-worn cameras ("BodyCams") or drone technology used for documentation, quality control, safety, and liability protection.

· Operational Data: Service dates, locations, crew details, chemical usage logs (where applicable), and communications related to service execution.

By engaging with SmartWash PRO through any channel or for any service vertical, you acknowledge and agree to the practices described in this comprehensive Privacy Policy.

11.2 Processing Principles

The Provider agrees to:

(a) Treat all Client information as confidential, in accordance with Section 8 (Confidentiality) of the Service Agreement;

(b) Limit data use to service execution, billing, quality control, regulatory compliance, and legitimate business operations as outlined in our Standard Operating Procedure (SOP);

(c) Implement and maintain technical and organizational measures to protect information against unauthorized access, loss, or alteration.

11.3 Collection and Use of Information

(a) Service Data: We collect only data necessary for service performance (e.g., aircraft tail number, contact information, service location) as specified in the Service Quotation/Work Order.

(b) Images & Recordings: Photographs, video, and BodyCam footage are used for quality control, pre/post-service condition documentation (walk-around inspection), and liability protection as defined in our SOP. Commercial or promotional use of images depicting Client property requires the Client’s express prior consent, revocable at any time via written notice to legal@smartwashpro.com.

(c) Website & Cookies: We collect information through our website to facilitate service requests and improve user experience. For details on cookies and tracking technologies, see Section 11.4 below.

11.4 Cookies & Tracking Technologies

Our website uses cookies and similar technologies. These are small data files placed on your device for essential site functionality, analytics, and performance. By using our site and agreeing to this policy, you consent to our use of cookies in accordance with this section. You can manage your cookie preferences through your browser settings.

11.5 Data Retention

Data is retained only as long as necessary for the purposes stated, or as required by law:

· Service records, contracts, and liability-related documentation (including images for damage claims): Up to 5 years, aligned with standard legal audit cycles and our insurance policy's claims reporting requirements.

· Financial and transactional records: Up to 7 years as required by Louisiana state law.

· Website analytics data: Retained according to our internal data retention policy for web services.

11.6 Disclosure to Third Parties

The Provider will not share Client data with third parties except:

(a) When required by law or a competent authority;

(b) With subcontracted providers bound by strict confidentiality obligations and only to the extent necessary for service execution;

(c) With our insurance carrier, Kinsale Insurance Company, as necessary to process or defend a claim, in accordance with the policy's "Claims Process" requirements.

11.7 Client Rights

The Client may:

(a) Request access to, correction of, or deletion of their personal data, subject to legal and contractual obligations that may require us to retain certain records;

(b) Revoke consent for the promotional use of images at any time;

11.8 Information Security

The Provider implements security measures including encrypted protocols for data transmission, restricted access controls, and incident response procedures to safeguard data.

11.9 Jurisdiction and Governing Law

This Privacy Policy shall be governed by the laws of the State of Louisiana, USA, including the Louisiana Data Privacy Act (LDPA), without regard to its conflict of laws principles. For Clients residing in Florida, this policy shall be interpreted to apply to the extent consistent with Florida law. Any disputes related to privacy shall be subject to the dispute resolution provisions in Section 9 of the Service Agreement.

11.10 Electronic Signatures & Records

You agree that your electronic signature, provided via our online service request and contract acceptance platform, is valid and binding under the U.S. Electronic Signatures in Global and National Commerce Act (ESIGN) and applicable state laws, including the Uniform Electronic Transactions Act (UETA) as adopted in Louisiana.