Privacy Policy SafeDrivePod

Version 10, 01/05/2024

This Privacy Policy is 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.

If you have any questions regarding this Privacy Policy, please send an email to our customer service team at: support@safedrivepod.com. Bji preferably include the word 'Privacy Policy' in the subject line.

"Personal Data" is data that identifies you or can reasonably be used to identify you or other individuals and is entered into the apps or site and/or collected by the apps or site and stored by SafeDrivePod in an accessible form. Examples of personal data include your name and your email address.

When you use the apps or site, you may be asked to provide certain information. Our services and products include the SafeDrivePod apps, for iOS and Android, for smartphone distraction, driving behaviour and crash response in combination with the SafeDrivePod hardware, the SafeDrivePod website, the SafeDrivePod dashboard that gives (fleet) managers an overview of all relevant data, the Corona tracer app and more. The personal data you provide us by using the apps or site are used by us primarily to ensure that the SafeDrivePod applications work. Furthermore, they are used to send you information upon request, to maintain contact with you, for market research and the preparation of (automatic) statistical analyses of our customers' profiles.

We use your data mainly and primarily to ensure that the SafeDrivePod applications work for greater safety while driving. Below we describe the different applications/services with the personal data we need to make them work.

For our app to work properly, we generally need your phone number to identify the smartphone paired with the SafeDrivePod so 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, unless otherwise agreed with the customer
• Type and version of the operating system (Android or iOS) of the phone used and the version of our app installed

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

Specific to the SafeDriveMotion functionality in the app (driving behaviour), we collect the following data:

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

Specifically for the SafeDriveResponse functionality in the app (crash detection), we collect the following data:

• 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)

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

In some cases, the SafeDrivePod app includes a so-called SOS button or 'Blue Button'. We record when these buttons are used. The SOS button activates the phone to call the emergency number and the blue button gives you full control of the phone again. Depending on the agreement with the customer, the number of Blue button uses is limited.

Fleet managers or similar officials who manage a group of cars or drivers can access our dashboard. The level of access to the data collected depends on the consents discussed with the customer and agreed in a separate Processor Agreement. We require the following data from this administrator: name, e-mail address and the name of the company they work for.

If you are not a customer or user of our system, you can still visit our website. You can fill in an online form to request information from us. To do so, we ask for the following data: your name and e-mail address so that we can contact you.

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 Google Analytics cookies. We have entered into a processor agreement with Google, which further excludes the sharing of Google Analytics data by Google with third parties. By masking the last octet of your IP address, we further enhance your anonymity.

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.

A Corona-Tracer stores the device numbers (so-called MAC addresses) of other Corona-Tracers when they come within 2m distance, in order to keep track of who someone has been in the vicinity of. If someone is sick, the Corona-Tracer is read out using an app, which sends the list as an excel file to a self-selected email address or own cloud drive. This data file is not sent to our server and so the data is not visible to us.

We do not ask for personal data when using the Corona-Tracer, except for the designated person within the company who uses the app to read out a Corona-Tracer in case of illness, for which a temporary password is issued by us. From this person, we request the email address to provide better support.

The link between MAC addresses and personal data is the responsibility of the company using the Corona-Tracers.

The data collected will be kept until the end of the contract period, unless you previously request that your data be deleted.

SafeDrivePod may combine personal data you provide to us through the app with personal data you have provided to us through other media, such as when you contact us by phone.

SafeDrivePod may combine personal data you provide us online with our offline data.

SafeDrivePod may combine personal information you have provided directly to us with data provided by third parties.

We mainly and primarily use this consolidated information to operate the SafeDrivePod application, providing you with additional safety while driving. We further use this consolidated information to help us improve the design of this app and other products, to improve our marketing and research activities, and to facilitate other business functions.

SafeDrivePod stores data on secure servers located in countries within the European Economic Area or other countries deemed to provide adequate protection for your personal data.

SafeDrivePod requires any entities outside the European Economic Area to which it transfers personal information to protect it in accordance with EU data protection standards.

In accordance with local law, you may request access to the data we collect about you at any time. You can also request to amend, correct or delete your personal data, or restrict processing. To do so, please contact us using the contact details below. If you request us to delete your personal data, this may mean that we can no longer offer you our services.

To ensure that the request for access is made by you, we ask that you send us an e-mail using the same e-mail address you used to register plus the last three digits of your telephone 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.

You agree that all database rights applicable to the personal data collected from you by SafeDrivePod are currently the responsibility of SafeDrivePod.

In the event that SafeDrivePod becomes the target of a takeover, merger, sale or other transaction and the database or the company owning the database is acquired by a third party, you will be notified by email. If you do not wish your personal data to be disclosed to its advisers and the acquiring third party both during and after the transaction, you may respond to this e-mail. If you do not give your consent, your data will not be disclosed, which may mean a discontinuation of services after the transaction is closed. Once the transaction is closed, you will be informed of the transaction and the ownership and control of the database and your personal data you have provided to SafeDrivePod. The personal data will be transferred to the third party in accordance with the terms and restrictions set out in this Privacy Policy. If the transaction is not concluded, SafeDrivePod will agree with the third party that they may not use your personal data.

Protecting your privacy is important to you and to us. That is why our systems and programmes are properly protected. We use management procedures to keep information accurate, current and complete and to prevent unauthorised persons from both inside and outside our organisation from accessing your personal data. This includes, but is not limited to, encryption of connections and content.

Although SafeDrivePod secures all personal data, we encourage you to exercise caution when sending personal data over the Internet.

If you are a SafeDrivePod customer with access to the SafeDrivePod dashboard, we may, with your explicit consent, send you information or otherwise contact you, regarding new services, features and other communications, in the form of an electronic newsletter or otherwise. You may also unsubscribe from these communications.

In many cases, you have received SafeDrivePod products and services through a third party, such as employer, insurer, leasing company and so on. This third party has insight into employee/customer data via a dashboard on the SafeDrivePod site. This can be just an overview of averages and/or totals, but can also provide insight into the data down to the individual level. It is therefore extremely important that the third party handles the data as carefully as we do.

Hence, we ensure that a so-called processor agreement is signed with each third party, which sets out the rights and obligations according to our Privacy Policy, before the third party is granted access to the dashboard.

In the event that any part of the terms of this Privacy Policy is declared invalid, the parties will remain bound by the remaining part. The parties will replace the invalid parts with valid provisions which, given the content and purpose of these terms and conditions, have legal force and are similar or as close as possible to the invalid part.

In accordance with applicable law, these terms and conditions are governed exclusively by the laws of the Netherlands. All disputes arising from these terms and conditions shall be settled by a competent court in Amsterdam.

SafeDrivePod reserves the right to make changes and/or updates to this Privacy Policy as a result of technological developments, changes in laws and regulations and for good business practice. We encourage you to save and refer to this webpage for the latest version of this Privacy Policy, identified by the date on the document.

If you have any questions regarding access to and use, modification, or deletion of personal data you have provided to us or if you no longer wish to receive further communications from SafeDrivePod, please contact us by sending an e-mail to support@safedrivepod.com. You may also send a letter to the following address:

SafeDrivePod International B.V.
Attn: data protection officer
Stationsweg 6a
6861 EG Oosterbeek

In all your communications with SafeDrivePod, please ensure that you include your email address and a detailed explanation regarding your request. If you wish to delete, amend or correct personal data and you contact us via email, please include 'Request for deletion' or 'Request for amendment/correction', as appropriate, in the subject line of your email. We will do our best to reply to all reasonable requests as soon as possible.