Privacy Notice

Privacy Notice for slugi66.com and the I-66 Slugging Challenge

Effective Date: July 20, 2026

This Privacy Notice explains how slugi66.com (the “Website”) and the I-66 Slugging Challenge (the “Challenge”), administered by AEM Corporation (“we,” “us,” or “our”), collect, use, share, and protect personal data. It also describes your rights under applicable law, including the Virginia Consumer Data Protection Act (VCDPA).

This Notice applies to:

your use of slugi66.com
your registration for and participation in the I-66 Slugging Challenge

1. Categories of Personal Data We Collect

We collect personal data from multiple sources, including directly from you, through the Website, and (with your consent) from third-party partners.

A. Information you provide directly

When you use the Website or register for the Challenge, we may collect:

Name
Email address
Communications you send to us
Commute-related information (such as travel times, slug line or employer location access and commuting patterns)
If voluntarily provided, additional commute details (such as slug line location, travel modes, commute duration, frequency, and costs)
Information about how you learned about the Challenge

B. Information collected automatically through the Website

When you visit slugi66.com, we may collect:

IP address
Device and browser type
Pages visited and links clicked
Date and time of visits
Referring URLs

This information may be collected using cookies or analytics tools and is used to:

operate and improve the Website
monitor performance and security
understand user engagement

C. Information received from Commuter Connections (with your consent)

We may receive data from the Commuter Connections program, a regional transportation program coordinated by the Metropolitan Washington Council of Governments, which includes services such as ridematching, the Guaranteed Ride Home program, and commuter incentive programs, including the Commuter Connections Rewards Program within the CommuterCash Mobile Application (“Commuter Cash”).

If you provide authorization, data received may include:

Account identifiers (such as email used to match accounts)
Trip-related information (such as trip timing, slug line or employer location access, and trip activity)
Information related to participation in Commuter Connections programs, including eligibility or enrollment status (such as participation in the Guaranteed Ride Home program), where relevant to the Challenge
Other Challenge-related commute or account data permitted to be shared

Sensitive Data Notice

Some trip-related data, particularly slug line or employer location access, may be considered sensitive personal data under Virginia law.

We process this information only with your consent, as provided through the separate Data Sharing Authorization accepted during Challenge registration.

2. Purposes for Processing Personal Data

We process personal data only for the purposes described below.

Website purposes:

To operate and maintain slugi66.com
To improve functionality and user experience
To monitor usage and ensure security

Challenge administration:

To register and manage participation
To verify eligibility for prize drawings
To validate entries and logged trips
To administer incentives and prizes
To communicate with participants regarding the Challenge (including updates, notifications, and post-Challenge feedback requests)
To announce and recognize Challenge prize winners in accordance with the Official Rules.
To prevent fraud and resolve disputes

Program evaluation and reporting:

To analyze commuting behavior and slugging participation
To evaluate outreach, communications, and incentives
To improve future program design
To prepare reports for sponsors and partners

Public reports will generally use aggregated or de-identified data.

Purpose limitation

We will not process your personal data for purposes that are not reasonably necessary or compatible with those described above without obtaining additional consent.

3. Disclosure of Personal Data

We may disclose personal data to:

Contractors and service providers supporting the Website or Challenge
Public-sector partners and program stakeholders
Auditors, legal advisors, or regulators where required

This may include:

AEM Corporation
Authorized contractors and agents
Public-sector project partners supporting the Challenge

We do not sell personal data.

We do not use Challenge-related data for unrelated third-party marketing.

Winner Recognition. If you accept a Challenge prize, we may publish your first name, morning slug line location, photograph, and likeness in connection with winner announcements and promotion of the Challenge, as described in the Official Rules. If a photograph is not provided, winner recognition may be limited to first name and morning slug line location.

4. Data Retention

We retain personal data only for as long as reasonably necessary to:

operate and improve the Website
administer the Challenge and award prizes
verify participation and resolve disputes
evaluate program outcomes
comply with legal, audit, and contractual obligations

After that, data will be deleted, anonymized, or aggregated.

5. Your Rights Under Virginia Law (VCDPA)

If you are a Virginia resident, you have the right to:

Access your personal data
Correct inaccuracies
Delete personal data
Obtain a portable copy of your data
Opt out of:
- sale of personal data (not applicable—we do not sell data)
- targeted advertising (not currently applicable)
- profiling that produces legal or similarly significant effects

How to exercise your rights

We will respond within the timeframe required by law.

Appeals

If we deny your request, you may appeal by emailing contact@slugi66.com with “Privacy Appeal” in the subject line.

6. Data Sharing Authorization (Important Notice)

Certain data processing activities, specifically the receipt of trip and account data from Commuter Connections programs, are conducted based on your separate Data Sharing Authorization provided during Challenge registration.

That authorization:

governs how data is shared from Commuter Connections
limits use of that data to Challenge-related purposes
excludes unrelated marketing uses
provides withdrawal rights

Participation in certain Challenge features may require registration with Commuter Connections and eligibility for its Rewards Program, which is administered through the CommuterCash Mobile Application (“Commuter Cash”).

7. Withdrawal of Consent

Where processing is based on consent (including Commuter Connections data sharing):

You may withdraw consent at any time by contacting us
Withdrawal applies prospectively
Withdrawal may affect prize eligibility or participation in Challenge features requiring data verification

8. Cookies and Tracking Technologies

The Website uses cookies and similar technologies to:

operate core functionality
analyze usage
improve performance

You can manage cookies through your browser settings.

9. Data Security

We implement reasonable administrative, technical, and physical safeguards designed to protect personal data from unauthorized access, use, or disclosure.

10. Third-Party Services

Your use of Commuter Connections and related services, including Commuter Cash, is governed by their respective privacy policies and terms of use.

We encourage you to review those policies before using those services.

11. Changes to This Notice

We may update this Privacy Notice periodically.

Updates will be posted on slugi66.com with a revised effective date.