Privacy Policy SafeDrivePod

Version 11, 12-11-2025

This Privacy Policy has been prepared by SafeDrivePod International B.V. , a Dutch company specialising in the development of traffic applications, and applies to this company and its subsidiaries and affiliates. These are collectively referred to as 'SafeDrivePod'.

SafeDrivePod values your privacy. Therefore, we have prepared this document describing how we collect and distribute your data when using SafeDrivePod software applications such as the SafeDrivePod apps and websites. When you start using the SafeDrivePod software applications, you will be shown this Privacy Policy and asked for your consent. The document explains why we collect certain personal data and how we protect the personal data you entrust to us. We also describe your rights and the conditions under which we provide you and others with data.

From 25 May 2018, the General Data Protection Regulation (GDPR) will apply. this means that from that date, the same privacy laws will apply throughout the European Union (EU). the AVG is also known by its English name: General Data Protection Regulation (GDPR). safeDrivePod's Privacy Policy has been drafted in accordance with this legislation.

This privacy statement applies to all processing of personal data by SafeDrivePod, including:

• The use of our website
• Provision of our products and/or services
• Customer service and support
• Marketing and communication
• Administrative purposes

We may process the following categories of personal data about you:

2.1 Contact details:

• First and last name
• Email address
• Telephone number
• Address details (street, house number, postcode, city)

2.2 Company details (if applicable):

• Company name
• Chamber of Commerce number
• VAT number
• Job title

2.3 Technical data

• IP address
• Browser type and version
• Device data
• Cookie data
• Log data of website visits

2.4 Transaction data

• Order information
• Invoice data
• Payment details

2.5 Communication data

• Correspondence via e-mail, telephone or other channels
• Feedback and reviews

2.6 Product-specific data

SafeDrivePod app

In order for our app to work properly, we generally need your phone number to identify the smartphone paired with the SafeDrivePod so that we know you are driving your car and not e.g. travelling by train. We need your email address to send you messages if you accidentally turned off the app or Bluetooth, and we ask for your name to be able to address you properly in our communications. We further collect data about the following, each timestamped:

• Whether you installed the app
• Whether you have connected to the SafeDrivePod hardware (the 'pod'), including the serial number
• Whether you have Bluetooth on/off
• Whether you have GPS on/off (if you choose to use GPS to determine whether you are driving or not; by default, the pod determines whether you are driving based on acceleration measurements and GPS is not used, but you can choose to have the phone's GPS determine whether you are driving if, for example, engine vibration interferes with acceleration measurements)
• Driving time
• Distance travelled (based on driving time with preset average speed, or based on actual GPS data, depending on user preference, see above)
• Number and duration of phone calls while driving, if set
• Type and version of the operating system (Android or iOS) of the phone used and the version of our app installed

SafeDriveMotion (driving behaviour)

• The number of hard and medium braking events per trip
• The number of hard and medium acceleration events per trip
• The number of hard and medium cornering events per trip
• The duration of a ride

We do not track how fast you drive or where you drive: therefore, we do not use or store location data from your phone, as we do not think it is necessary to understand your driving behaviour and it would be too much of an invasion of your privacy.

SafeDriveFocus (phone distraction)

Specific to the SafeDriveFocus functionality in the app (preventing distractions) and specific to iPhone users, we count the number of times you tried to unlock the phone while driving.

SafeDriveResponse (crash detection)

• The G-force of a crash if the impact exceeds a certain minimum G-force
• Collision position (left/right/front/rear)
• The date and time of the event
• The location of the crash based on GPS data from the phone, if authorised by you (this is the only time we use your location information to help you at a moment of stress)

Please note: These product-specific data may be subject to additional processing purposes and retention periods explained below.

2.7 Cookies

SafeDrivePod's apps and websites only use temporary cookies or so-called session cookies to establish a connection. Session cookies are temporary pieces of information that are deleted as soon as you switch off your device.

The SafeDrivePod sites ask you for permission to use Hubspot and LinkedIn cookies.

The use of cookies is secure. Personal data such as a phone number or an e-mail address cannot be traced by setting cookies. As a result, cookies cannot be used for sending e-mails or telemarketing purposes. You can find more information about cookies at www.allaboutcookies.org.

We process your personal data only for specific purposes and on a valid legal basis:

3.1 Performance of contract (Art. 6(1)(b) AVG)

• Purpose: Delivery of products and services, order processing, customer service
• Data: Contact data, company data, transaction data

3.2 Legitimate interest (Art. 6(1)(f) AVG)

• Purpose: Website security, fraud prevention, improvement of our services
• Data: Technical data, IP addresses, log data
• Balance of interests: Our legitimate interest in security outweighs your privacy impact

3.3 Legal obligation (Art. 6(1)(c) AVG)

• Purpose: Accounting, tax obligations
• Data: Invoice data, transaction data

3.4 Consent (art. 6 paragraph 1 sub a AVG)

• Purpose: Newsletter, marketing communication (only with your explicit consent)
• Data: E-mail address, communication preferences

3.5 Product-specific processing

SafeDriveMotion

• Legal basis: Performance of contract and legitimate interest (road safety)
• Purpose: driving behaviour analysis, safety assessment
• Data: see 2.6

SafeDriveFocus

• Legal basis: Performance of contract and legitimate interest (road safety)
• Purpose: Preventing phone distraction while driving, safety improvement
• Data: see 2.6

SafeDriveResponse

• Legal basis: Performance of contract and legitimate interest (road safety). In particular, the exception of using location data in this situation only serves the user's interest as help can be delivered more accurately and faster.
• Purpose: recognising an accident so that appropriate assistance can be provided
• Data: see 2.6

We do not retain your personal data for longer than necessary for the purposes for which it was collected:

• Administrative data: 7 years (legal retention obligation)
• Website log files: 2 years
• Marketing data: Until you unsubscribe or object
• Customer service data: 3 years after last contact or until you object
• Cookie data: According to cookie policy (maximum 24 months)
• SafeDriveMotion data: Until you unsubscribe or are unsubscribed (end of contract) or object
• SafeDriveFocus data: Until you unsubscribe or are unsubscribed (end of contract) or object
• SafeDriveResponse data: Until you unsubscribe or are unsubscribed (end of contract) or object

We never sell your data to third parties. We only share your data in the following cases:

5.1 Processors

• Hosting provider: CloudVPS/TransIP for website hosting
• E-mail provider: Google for e-mail communication
• Bookkeeper/accountant: For administrative obligations

5.2 Legal requirements

We may share your data when required by law or necessary for legal proceedings.

If we transfer your data to countries outside the European Economic Area (EEA), we ensure adequate protection by:

• Adequacy decisions of the European Commission
• Standard contractual clauses (CPCs)
• Other appropriate safeguards in accordance with the AVG

We take appropriate technical and organisational measures to protect your personal data against:

• Unauthorised access
• Loss or destruction
• Unlawful processing
• Data breaches

These measures include:

• SSL encryption for our website
• Access restriction to personal data
• Regular security updates
• Staff awareness and training

We are ISO27001 certified.

In the event of a merger, acquisition, reorganisation or other change in SafeDrivePod's corporate structure, personal data may be transferred to or shared with the successor organisation(s).

In this case, we will ensure that this party uses the personal data only for the same purposes for which it was originally collected, and that an adequate level of protection is ensured.

If the nature of the processing changes substantially, we will inform the data subjects in a timely manner and - if necessary - seek their consent again.

You have the following rights regarding your personal data:

9.1 Right of access (Art. 15 AVG)

You may request access to the personal data we process about you.

9.2 Right to rectification (art. 16 AVG)

You can request correction of incorrect or incomplete data.

9.3 Right to erasure (art. 17 AVG)

You can request deletion of your personal data ("right to be forgotten").

9.4 Right to restriction (Art. 18 AVG)

You can request restriction of the processing of your data.

9.5 Right to data portability (Art. 20 AVG)

You can request your data in a structured format for transfer to another organisation.

9.6 Right to object (Art. 21 AVG)

You can object to certain processing operations, in particular for marketing purposes.

9.7 Right to withdraw consent (Art. 7 AVG)

If we process your data on the basis of consent, you can withdraw it at any time.

To exercise your rights, please contact us at:

• E-mail: info@safedrivepod.com
• Postal address: SafeDrivePod International B.V.
  Attn: Data Protection Officer
  Stationsweg 6a
  6861 EG Oosterbeek

To ensure that the request for access is made by you, we ask you to send an e-mail with the same e-mail address you used to register plus the last three digits of your telephone number. We will respond to your request within one month. In complex cases, we may extend this period by up to two months.

We may inform users of our products and services about important service or security updates necessary for the use of our products.

In addition, based on your consent or our legitimate interest, we may send information about new products, features or relevant developments at SafeDrivePod.

You can unsubscribe from these non-essential communications at any time via the unsubscribe link in the app or by contacting us at the email address listed below.

To ensure that the request for access is made by you, we ask that you send us an email using the same email address you used to register plus the last three digits of your phone number. We will respond to your request as soon as possible, but within four weeks.

You have the right to submit a complaint to the data protection officer (see address below) or to the management of SafeDrivePod International BV.

Do you have any complaints about the processing of your personal data? If so, please contact us first. You can also file a complaint with the Personal Data Authority:

Personal Data Authority
PO Box 93374
2509 AJ The Hague
Phone number: 088 - 1805 250
Website: www.autoriteitpersoonsgegevens.nl

We may update this privacy statement from time to time. Changes will be published on our website. In case of important changes, we will inform you via e-mail or a notification on our website. This privacy statement has been prepared in accordance with the General Data Protection Regulation (AVG/GDPR) and was last updated on 12 November 2025.

SafeDrivePod International BV
Address: Stationsweg 6a, 6861 EG Oosterbeek, the Netherlands
Chamber of Commerce number: 68329717
VAT number: NL857395476B01
E-mail: info@safedrivepod.com
Telephone: +31(0)262022988