Version 2027-01-01-sample · published November 8, 2026
SAMPLE — ILLUSTRATIVE VALUES ONLY — DRAFT FOR ATTORNEY REVIEW — NOT LEGAL ADVICE — NOT FOR PUBLICATION OR SIGNATURE
Version 0.1-sample — 2026-11-08
Effective date: January 1, 2027 — Last updated: November 8, 2026
This Privacy Policy explains how eCashToll, LLC ("eCashToll," "we," "us") collects, uses, shares and protects personal information when you use the eCashToll app, website, prepaid toll account, cards and gift cards (the "Service").
Note to counsel: Memo Q10. Please confirm which state laws apply at launch (thresholds), whether a GLBA privacy notice is also required (Q10(f)), and whether a separate "Notice at Collection" or in-app just-in-time notices are needed. This draft is written to satisfy the most demanding of the VA/TX/NJ regimes regardless of thresholds.
| Category | Examples | Notes |
|---|---|---|
| Contact / identifier | Mobile phone number; email address if you provide one | Phone number is your sign-in |
| Vehicle | License plate state and number; vehicle class; nickname you give the vehicle | |
| Support | Messages to support, dispute details, copies of toll notices you send us | |
| Refund details | Name and mailing address if you request a refund by check | Collected only when needed |
| Gift Card recipients | Recipient phone number and optional message when you send a Gift Card | See Section 4.5 |
| Category | Examples |
|---|---|
| Toll transactions | Agency, facility, plaza/gantry, date and time, plate, vehicle class, Agency Charge, eCashToll Fee, dispute status |
| Account activity | Loads, Card redemptions (Card number and redemption time), Holds, Balance history, Suspension and re-activation events, plate enrollment status |
| Payment references | Payment provider transaction IDs, payment method type and last four digits/brand as provided by the provider, PayPal/Venmo reference IDs. We do not receive full card numbers, bank account numbers or security codes. |
| Card data | For eCashToll Cards: Card number, a salted hash of the PIN (never the PIN itself), status, retailer/distributor and store location and state of sale |
| SMS records | Messages sent, delivery status, opt-in and opt-out records |
If you turn on trip tracking and grant location permission, the app collects GPS points (latitude, longitude, time, speed, heading, accuracy) while a trip is being recorded so it can estimate tolls, show trip history and place Holds. The app collects location in the background during an active trip. You can turn this off at any time in the app or your device settings.
Note to counsel: Confirm with engineering whether collection is only while the app is in use or in the background during an active trip (this sample assumes background); background collection requires a more prominent disclosure under Google Play policy and state law.
Device model, operating system version, app version, device identifiers used for push notifications and fraud prevention, IP address, language, crash and diagnostic logs.
| Source | Information |
|---|---|
| Toll agencies and toll processors | Posted toll transactions for enrolled plates; plate enrollment acceptance/rejection; dispute decisions; images of the vehicle/plate related to a disputed toll |
| Distributors and retailers | Card activation and void records, store/location of sale, direct-load phone number and amount |
| Payment providers | Payment status, references, chargebacks, fraud signals |
| SMS provider | Delivery receipts, opt-out (STOP) records |
Note to counsel: DPPA — Memo Q10(d). Our design does not request registered-owner names or addresses from agencies. If an agency sends DMV-derived data (e.g., with a violation or plate verification), we need a DPPA permissible-use basis and re-disclosure controls. Please advise whether to add a specific DPPA statement here.
| Purpose | Information used |
|---|---|
| Create and secure your Account; sign you in by text code | Phone number, device info, SMS records |
| Enroll and remove plates at toll agencies; pay tolls; charge your Balance | Plates, vehicle class, toll transactions, Balance |
| Show trips, estimates, Holds and the three-price comparison | Location (if allowed), toll transactions, agency rate tables |
| Process loads, Card redemptions, Gift Cards, refunds and chargebacks | Payment references, Card data, refund details |
| Send sign-in codes, low-balance and Suspension alerts, Gift Card texts | Phone number, recipient phone number |
| Handle disputes and customer support | Toll transactions, support messages, toll notices |
| Prevent fraud, abuse and toll evasion; enforce our Terms | All categories as needed |
| Comply with law, audits, tax, unclaimed-property and agency agreement requirements | All categories as needed |
| Improve the Service (in de-identified or aggregated form where possible) | Usage and diagnostic data; aggregated trip data |
We do not use your location or toll history to target advertising, and we do not build profiles to make decisions that produce legal or similarly significant effects about you, other than fraud screening and the automatic Suspension described in the Terms (which is based solely on your Balance).
We share personal information only as described below. We do not sell personal information and do not share it for cross-context behavioral (targeted) advertising.
4.1 Toll agencies and their toll processors. We send your plate state, number and vehicle class (and the dates the plate is active on our account) to the agencies where your plates are enrolled, directly or through the agency's back-office vendor, by secure connection. We do not send your phone number, name or location. Agencies send back the tolls those plates incur. Agencies are governmental or quasi-governmental bodies and their own laws and policies (including public-records laws) apply to information they hold.
Note to counsel: Memo Q14 — public-records exposure.
4.2 Payment providers (Stripe, PayPal, Venmo) to process payments, refunds and chargebacks, and to prevent fraud. Their own privacy policies apply to information you give them directly.
4.3 SMS provider (Sample SMS Gateway, Inc. — fictional sample name) to deliver text messages and process opt-outs.
4.4 Distributors and retailers to activate, void and settle Cards and direct loads. We share Card numbers and activation status, and for direct loads, the phone number and amount. We do not share your toll or location history with them.
4.5 Gift Card recipients and senders. When you send a Gift Card, we send the recipient a text that may include your first name or a message you write. We tell the sender whether the Gift Card was redeemed, but not who redeemed it beyond the recipient's phone number the sender entered.
4.6 Service providers that host and operate the Service for us under contract, such as cloud hosting (Amazon Web Services), databases, email, customer support, analytics and crash reporting. They may use the information only to provide services to us.
4.7 Legal, safety and enforcement. When required by law, subpoena or court order; to protect the rights, property or safety of eCashToll, our customers or others; to investigate fraud; and, for toll disputes, with the relevant agency.
Note to counsel: Several states treat toll records as confidential and restrict disclosure to law enforcement without process — Memo Q10(e). Consider a stated policy of requiring legal process.
4.8 Business transfers. In a merger, acquisition, financing, or sale of assets, subject to this Policy.
4.9 With your consent or at your direction.
5.1 Precise geolocation is sensitive personal data under several state privacy laws. We collect it only after you opt in in the app, separately from accepting our Terms.
Note to counsel: Draft consent screen text: "Allow eCashToll to use your precise location during trips to estimate tolls, place holds on your balance and show your trip history. We don't sell your location or use it for ads. You can turn this off at any time."
5.2 We use location only for the purposes in Section 3. We do not share raw GPS points with toll agencies, distributors or advertisers.
5.3 Raw GPS points are kept for 12 months and then deleted or de-identified (see Section 6). Toll transactions are kept longer because they are financial records.
5.4 You can use the Service without location; posted tolls are still charged.
We keep information only as long as needed for the purposes above:
| Information | Retention |
|---|---|
| Raw trip GPS points | 12 months from the trip, then deleted or de-identified |
| Toll transactions, loads, redemptions, refunds | 7 years after the transaction (financial, tax, audit and agency-agreement requirements) |
| Account and plate history | Life of the Account plus 3 years |
| SMS logs and consent records | 5 years (Note to counsel: TCPA statute of limitations.) |
| Support records | 3 years |
| Demo Account trip data | 90 days after last use |
| Card records (unredeemed / redeemed) | Unredeemed: until reported as unclaimed property; redeemed: 7 years after redemption |
Note to counsel: Business decision §4.11; confirm against agency agreement record-retention and audit clauses and unclaimed-property recordkeeping.
We use administrative, technical and physical safeguards appropriate to the sensitivity of the data, including: encryption in transit (TLS) and at rest; Card PINs stored only as salted hashes; sign-in by one-time code; access controls and logging for staff; secure file transfer (SFTP) or authenticated HTTPS APIs with toll partners; and payment data handled only by PCI-compliant providers. No system is perfectly secure. If a breach affects your personal information, we will notify you and regulators as required by law.
8.1 All users. You can: view your plates, trips and toll history in the app; correct your plates and vehicle class; turn location off; opt out of non-essential texts by replying STOP; and close your Account.
8.2 Residents of Virginia, Texas, New Jersey and other states with comprehensive privacy laws. Subject to exceptions in those laws, you have the right to:
How to make a request: in the app under Settings > Privacy, by email to privacy@ecashtoll.com, or at 1-800-555-0199. We verify requests by sending a code to the phone number on the Account. You may use an authorized agent where the law allows. We will respond within the time required by law (45 days, extendable as permitted). If we deny your request, you can appeal by emailing privacy@ecashtoll.com with "Appeal" in the subject line. If your appeal is denied, you may contact your state Attorney General.
We will not discriminate against you for exercising your rights. We honor recognized universal opt-out signals (such as Global Privacy Control) where required, though we do not sell or target-advertise.
Note to counsel: Confirm each state's response time, appeal requirement, and whether NJ requires additional disclosures (e.g., for consumers under a certain age). Pennsylvania: no comprehensive privacy statute known to us — confirm.
8.3 Other states. We will consider requests from residents of other states and respond as required by applicable law.
The Service is for adults 18 and older. We do not knowingly collect personal information from children under 13 or from minors under 18. If we learn we have, we will delete it. Contact privacy@ecashtoll.com.
We will post changes here and update the date above. For material changes we will notify you in the app and by text before they take effect. We will ask for your consent where required (for example, before using sensitive data for a new purpose).
eCashToll, LLC — Attention: Privacy 100 Sample Plaza, Suite 200, Philadelphia, PA 19103 privacy@ecashtoll.com — 1-800-555-0199