Privacy Policy – Inteo IT Development

Version: July 2022

The information provided below gives you an overview over the Processing of your Personal Data by us and your rights under data protection law in connection with the use of our app for procuring Journeys for Drivers (“Flux Pilot App”).

Which Personal Data is processed is substantively determined based on the services or products you use.

Table of Contents

1. Information Regarding the Data Controller

2. Definitions

3. Data Processing Processes and Purposes

4. Data Exchange between Inteo IT Development and the Dispatch Service

5. Your Rights

6. Data Security

7. Storage Period

8. Updates and Changes

1. Information Regarding the Data Controller

For Drivers in the territory of Romania, the data controller as per Art. 4 No. 7 GDPR is:

Inteo IT Development S.R.L. (“Inteo”)

Address: Str. Emil Racoviță nr. 70 Camera 1, Bl. 2 Sc.1 Et. 3, Voluntari, jud. Ilfov

Phone: +0724541347

E-Mail address: contact@inteo.ro

2. Definitions

“Personal Data“ is all information which relates to an identified or identifiable natural person. Among these are, for example, name, postal address, e-mail address or telephone number, but also usage data like your IP address.

“Processing“ is every process carried out with or without automated assistance or every sequence of such processes in connection with Personal Data, e.g. obtaining, capturing, organizing, ordering, saving,

adjusting or modifying, sorting, accessing, using, disclosing by transmission, distributing or any other form of making available, comparing or connecting, limiting, deleting or destroying.

Transportation Company: means any independent contractor or legal entity that legally owns / uses a

transport license or authorization issued in accordance with the provisions of Law no, 38/2003 and/or

Government Emergency Ordinance no. 49/2019, who has an user account on the Dispatcher platform

created by means of a legal or conventional representative, and with whom Inteo IT Development has a direct contractual relationship for intermediation services offered by means of the Flux platform. This

definition shall also refer to those persons authorized to perform activities for which Inteo IT Development offers intermediation services, other than the transportation activities regulated within the legal framework mentioned above.

The easiest way to reach our data protection officer is via e-mail: contact@inteo.ro or by writing to the

foregoing address with the subject: “For the attention of the Data Protection Officer.”

3. Data Processing Activities and Purposes

In the following, we will inform you about the various types of Personal Data we process and for what purpose. The Flux Pilot makes it possible for you to see and participate on advertised Rides from Passengers. For the use of our Flux Pilot App for bidding to Rides, you must provide Personal Data which we process in order to perform the respective service. If additional information can be voluntarily shared, these are indicated as being “optional“.

3.1 Rides bidding

In connection with the rides advertising service, pursuant to Art. 6 (1) b) GDPR, for the purpose of performing our ride advertising framework contract with you or, as it may be, your Transportation Company, and pursuant to Art. 6 (1) a) GDPR as it relates to optional information, the following Personal Data is processed:

3.1.1 General

For your registration and use of the Flux Pilot App, we may ask from you and will process the following personal information about you:

First name and surname, country, email address, mobile phone number, information regarding your professional license as well as about your driver license, car registration number, transport authorization, your GPS coordinates (location data) while being logged into the Flux Pilot App at the time of starting the shift by the time of ending the shift, information regarding your end user device (Device ID, time of access of the Flux Pilot App, phone type and operating system, carrier), information regarding the Transportation Company (for Drivers who are employees), statements regarding rating by passagners (1 to 5 stars for the Driver / vehicle as well as average rating), incidents regarding trips if reported by passangers, license plate number, color and make of the vehicle, readiness status, number of rides, revenue, rate of successful vs unsuccesful rides. The above personal information is processed by us based on (i) our legal obligation based on art. 6 (1) c) GDPR, (ii) contractual performance based on art. 6 (1) b) GDPR and (iii) our legitimate interest based on art. 6 (1) f) GDPR.

Your location data will be processed by Inteo IT Development based on art. 6 (1) c) GDPR, namely in order to comply with the legal obligation of Inteo IT Development to ensure means for the continuous monitoring of the rides, as expressly stated within the Romanian applicable legislation or based on our legitimate interest, in accordance with art. 6 (1) f) GDPR or based on a contractual obligation in accordance with art. 6 (1) b) GDPR, based on the contract concluded with the Transportation company or directly with you.

For the purposes of coordination we share your GPS coordinates with the Dispatching Service to allow it to prioritize rides based on time spent in stations, proximity to orders and other factors.

For purposes of identification, we show your GPS coordinates as well as your name and, insofar as it has been provided to us, your profile picture and the license plate number to the Passenger who has advertised the ride that you bid on.

In order for the Dispatching Service to keep the priority among the drivers when multiple drivers bid on the same ride, you need to share your location details permanently with the Dispatching Service. If for whatever reason you are not sending location data to the service, the Dispatch Service will not be able to keep you place in the priority queue, and your place in the queue will be reset.

That means keeping the application connected and in the foreground for as long as you want your priority to be taken into consideration. You can choose to provide your location data while the application is in the background (optional input) so you can operate the device for other purposes while waiting in station and still keep your place in the priority queue.

Without the Processing of the foregoing Personal Data, we cannot operate the ride bidding system, and cannot cannot advertise bids for you through your Transportation Company. This does not apply to optional inputs.

3.1.2 Integration of Google Maps

The Flux Pilot App uses the Google Maps API which is provided by Google Ireland Limited Gordon House, Barrow Street Dublin 4 (“Google”). In this way, you can be shown maps in the Flux Pilot App and you can also have the ability to interact with said maps. Without the Google Maps API application, Flux Pilot App will not function. The terms of use for Google Maps can be found at: https://www.google.com/help/terms_maps.html. There, you will also find a notice regarding the privacy policy of Google: https://policies.google.com/privacy?hl=de. We use Google Maps in order to interactively show you the distance to the Passenger who advertised the ride. We process your GPS coordinates in accordance with Art. 6 (1) c) GDPR namely based on a legal obligation. Your GPS coordinates will only be transmitted to Google in an anonymized manner. An identification of your person is impossible.

3.3 Rating of Drivers and Passengers

Via the Passenger App, Passengers can rate you and your vehicle after a ride with a rating between 1 to 5 stars. The individual rating flows into the average value which we have determined for you and your vehicle. The individual rating is visible to the respective Passenger who provides it, to you as the Driver and to the Dispatching Service. For Drivers who are employed with a Transportation Company, we will transmit the individual rating to your Transportation Company.

Further, Passengers can add Drivers as favorite Drivers in their Passenger App profiles. In this context, your first name and surname, your rating and the profile picture will be saved in the Passenger App of the respective Passenger.

The Processing of this data takes place based on a legal obligation pursuant to Art. 6 (1) c) GDPR or on the basis of our legitimate interest pursuant to Art. 6 (1) f) GDPR to implement a system for verifying the quality of the Ride and ensure Passenger security.

3.4 Fraud Prevention

3.4.1 GPS Tracking

In order to prevent fraudulent behavior, we save the GPS coordinates transmitted by your mobile device during a ride which, thus, makes it possible for us to depict the entire course of a Ride. By doing this we wish to ensure that Drivers do not intentionally prolong the ride in order to obtain a higher compensation. At the same time, we can correct unjustified Passenger complaints by presenting the actual course of a Ride. The Processing of your GPS coordinates takes place during the course of a ride for your own protection and for the protection of the Passenger, as well as on the basis of Art. 6 (1) c) GDPR, for compliance with our legal obligation as ridesharing digital platform operators and for our own protection on the basis of Art. 6 (1) f) GDPR.

3.5 Bug Fixing and Functionality Improvements

In order to fix bugs in the Flux Pilot App and to improve functionality of the Flux Pilot App and to adjust it to suit the needs of Drivers and the Dispatch Service, we process the following Personal Data pursuant to Art. 6 (1) f) GDPR on the basis of our legitimate interest:

First name and surname, date of birth, city, country, e-mail address, mobile phone number, information regarding your license, your GPS coordinates while being logged into the Flux Pilot App and at the start of shift to the and of shift, time of starting and during the course and at the destination of a particular ride, information regarding your end user device (Device ID, time of access of the Flux Pilot App, phone type, operating system, carrier), information regarding the Transportation Company (for Drivers who are not themselves Transport Companies), company address (for Drivers who are, at the same time, Transportation Companies), information regarding the rating of Passengers (1 to 5 stars for the Driver and the vehicle as well as the average rating), license plate, color and make of the vehicle, readiness status, number of Rides, rate of sucessful or unsuccesful rides.

Inasmuch as it is sufficient for the performance of the respective purpose, we work with anonymous data and not with Personal Data.

4. Data Exchange between Inteo IT Development and the Dispatch Service

For administration and standardization purposes, we may transfer personal data of drivers or passengers with the Dispatch Service. The legal basis for this is our legitimate interest in effective company management, Art. 6 (1) f) GDPR, see also Recital 48 to the GDPR. You will have a separate privacy policy with your Dispatch Service

5. Your Rights

If Personal Data belonging to you is processed, you are a data subject in the sense of GDPR and you have the following rights vis-à-vis Inteo IT Development:

You can, at any time, free of cost, obtain information regarding the extent, the origin and the recipient of retained data as well as the purpose of the retention (Art. 15 GDPR). You can, at any time, ask for incorrect data to be corrected (Art. 16 GDPR). Additionally, you have the possibility of receiving Personal Data related to you in a structured, common and machine-readable format (Art. 20 GDPR).

You can object to the usage of your Personal Data for the future (Art. 21 GDPR).

You can also ask for a partial or complete deletion (Art. 17 GDPR), limitation of Processing or a block (Art. 18 GDPR) of your Personal Data. We will examine this claim and, if there is no other statutory basis for the continued Processing, we will comply. We will inform you regarding the result.

Irrespective of any other administrative or judicial legal remedy, you have the right to file a complaint regarding the Processing of your Personal Data by us with a data protection authority.

All informational requests, queries, withdrawals of consent, objections or other issues regarding data protection can also be sent by e-mail to contact@inteo.ro or to the address stated in the introduction.

6. Data Security

We have taken appropriate technical and organizational measures to guarantee data security, in particular to protect your Personal Data against access by third parties, as well as accidental or intentional modification, loss or destruction. Such measures are reviewed periodically and adapted in line with the state of the art. The transfer of your Personal Data from your end user device (e.g. smartphone) to us is always encrypted.

7. Storage Period

The data provided by you to us is only stored for as long as is required to perform the respective purpose for which you have transmitted your data but at least 2 years as of the date when your registration in the Flux Pilot App terminates, in accordance with the applicable legal requirements. At the end of the retention period, the data will be anonymized by us, unless we have a legitimate interest in a longer storage period (e.g. bookkeeping requirements).

Details on every Ride performed by means of the Flux Pilot App shall be stored for at least 5

years, in accordance with the law. Your financial data may be stored for a longer period of time in accordance with the law, namely for at least 10 years for accountancy and fiscal purposes.

8. Updates and Changes

We retain the right to modify this privacy policy in the future. In case we change the privacy policy, we will inform you regarding such changes in a timely manner and will offer you the opportunity to consent or reject.