Privacy Policy

TowingOS · Carlyle Acquisition LLC d/b/a Legacy Tow Group · Effective September 1, 2026

1. Who we are

TowingOS is the internal operating platform of Carlyle Acquisition LLC d/b/a Legacy Tow Group (“Legacy Tow Group”, “we”, “us”) and its affiliated operating companies. It is not a consumer product and is not offered to the public. Access is limited to authorized employees, officers and contractors of Legacy Tow Group and its affiliates, and to advisors we expressly invite. Mailing address: 10151 Deerwood Park Blvd, Building 200, Suite 200, Jacksonville, Florida 32256.

2. What data the platform holds

TowingOS consolidates operating and financial data from systems Legacy Tow Group already uses:

• Accounting — QuickBooks Online and QuickBooks Desktop: chart of accounts, general ledger detail, transactions, trial balance and financial statement reports, customer and vendor records, and accounts receivable and payable agings.
• Operations — dispatch and job records, vehicle telematics, fleet and driver rosters.
• Commercial — CRM pipeline and account records.
• Spend and payroll — corporate card activity, payroll runs and pay-period aggregates.
• Correspondence — messages in shared company mailboxes used for accounting workflow (remittance advices, deposit notices, vendor invoices), and documents in company file storage.
• Platform accounts — the name, work email address and role of each authorized user, and a log of actions taken in the platform.

3. QuickBooks data specifically

When an authorized user connects a QuickBooks company to TowingOS, we read accounting data from that company through Intuit’s APIs and store it so it can be reported on. We use it for one purpose: internal financial reporting, reconciliation and period close for the connected entity. We do not sell it, rent it, share it with advertisers, use it to build products for third parties, or disclose it outside Legacy Tow Group except as described in section 6. Access tokens issued by Intuit are encrypted at rest with an application key and are never displayed in the interface.

Disconnecting a company (Accounting → Ledgers → Disconnect) revokes and deletes the stored tokens and stops all further syncing for that company immediately.

4. How we use data

• Producing management reporting, KPI scorecards and period-close workpapers.
• Reconciling bank activity, receivables and payables against the accounting records.
• Operational decision support — dispatch, fleet utilization, collections and billing workflow.
• Reporting to our lenders, auditors, board and equity sponsor.
• Securing, maintaining and troubleshooting the platform.

We do not use this data for advertising, and we do not make automated decisions that produce legal effects about any individual.

5. Where data is held

Platform data is stored in a managed PostgreSQL database hosted in the United States and served from hosting infrastructure in the United States. Data is encrypted in transit (TLS) and at rest. Access requires an authenticated account with a role that permits the module in question.

6. Who we share data with

We share data only with: (a) service providers that host or process it on our behalf under contract (hosting, database, email, and the source systems listed in section 2); (b) our independent accountants, auditors, lenders and equity sponsor, in the ordinary course of financial reporting; and (c) where required by law or legal process. We never sell personal information.

7. Retention and deletion

Accounting records are retained for the periods our audit, tax and lender obligations require. Operational records are retained while they remain useful for reporting. You may request deletion of data associated with a connected QuickBooks company, or of a platform user account, by writing to lshively@legacytowgroup.com; we will action it subject to any legal retention obligation.

8. Your choices

Authorized users may request access to, correction of, or deletion of personal data we hold about them by writing to lshively@legacytowgroup.com. Company administrators may disconnect any connected system at any time.

9. Security

Access is role-based and limited to company accounts. Credentials and third-party tokens are encrypted. We review access periodically. No system is perfectly secure; if a breach affecting personal data occurs we will notify affected parties as required by applicable law.

10. Children

TowingOS is a workplace tool. It is not directed to anyone under 18 and we do not knowingly collect data from children.

11. Changes

We may update this policy. The effective date above changes when we do, and material changes will be communicated to authorized users.

12. Contact

Questions about this policy: lshively@legacytowgroup.com, or write to us at 10151 Deerwood Park Blvd, Building 200, Suite 200, Jacksonville, Florida 32256.

QuickBooks and Intuit are trademarks of Intuit Inc., used here for identification only.