Company Internal

WHEN USING DRIVEY MOBILE APP

Publication date: 04/02/20

The Mobile Application Privacy Policy (hereinafter referred to as the "Privacy Policy")

governs the processing of information about users of the Drivey Mobile Application using

automation via the Internet.

This Privacy Policy explains the types of information we collect, how we use, share, and

secure the information you provide. It also describes your choices regarding use, access and

correction of your personal data.

Personal data is any personal information that allows a third party to identify an

individual (data subject).

Personal data is processed within the EU. Our activities are governed in accordance with

the General Data Protection Regulation (EU) 2016/679 (the “GDPR”), other applicable European

data protection laws, depending on which country you are located, collectively hereinafter

referred to as the Legislation. GDPR is a directly binding legislative act which protects

fundamental rights and freedoms of natural persons and in particular their right to the

protection of personal data.

We process your personal data only if one of the conditions specified in Article 6 of the

GDPR is fulfilled, including, but not exclusively:

- you have consented to the processing of your personal data;

- processing is necessary in order to provide you with services;

- such processing is required by the laws of the countries in which you are located.

Vayosoft considered to be the data controller and will determine the purposes and

means of the processing of personal data.

In this Privacy Policy, unless otherwise defined herein, the capitalized terms below shall

have the same meaning as in our Terms of Service.

Section I

General provisions

The Drivey mobile application is the property of Vayosoft Limited Liability Company

located at: 4 Rambam St., Office 35, Beer Sheva, 8420954, Israel (hereinafter referred to as the

Company).

The Drivey Mobile Application (hereinafter referred to as the Mobile Application) is a

telematics system for the remote monitoring of road transport.

By downloading, installing on your mobile device or using the Mobile Application in any

other way, You, as a Mobile Application User, agree to the terms of the Privacy Policy, agree to

abide by its provisions and consent to the processing of your information obtained through the

Mobile Application in accordance with the Privacy Policy.

Warning! If you do not agree to the Privacy Policy, you cannot use the Mobile

Application, including downloading or installing it on your mobile device.

Company Internal

For the purposes of the Privacy Policy, the term "information" is used in all cases for

data specified by the User or information about the User's activity, including personal data of

the User, if the User's identity is identified or can be specifically identified.

Withdrawal of consent. The User may withdraw his / her consent to the Privacy Policy

by sending a corresponding message to the Company's email address: . To

expedite the response, please indicate "Withdrawal of consent" in the subject line of the

message. Due to the fact that the information to be processed is required for the Mobile

Application to operate, the User's account will be deactivated and access to the Mobile

Application will be revoked after withdrawal of consent to the Privacy Policy.

Section II

Information collected by the Mobile Application and the purpose of its collection

If you would like to benefit from our services and submit information to us, you may be

asked to provide personal data in order for us to operate and improve our business and

services. Personal data may be submitted via our mobile apps, email, other electronic or

software solutions supported by us or postal service. All personal data is collected in

accordance with the GDPR. We will process personal data only to the extent required for a

specified, explicit and legitimate purpose or for a purpose required by law in places where we

operate.

Information provided by the User.

When using the Mobile Application User, the latter collects the following information

about the User: the User's mobile phone number, the User's vehicle information.

The mobile application collects information about the User, even in cases where the

User needs to contact customer support.

Upon consent we are allowed to send marketing e-mails. This specific form of consent

must be freely given, specific informed and unambiguous. These requirements are fulfilled

when during registration in the Mobile Application you opt-in to receive marketing e-mails

(actively agreed).

You will always have the right to object, on request and free of charge, to the processing

of your personal data relating for purposes of direct marketing activities without having to

provide specific justifications. You can do so by using button the “Unsubscribe” found in Mobile

Application. If you object, your personal data will no longer be processed for direct marketing.

The marketing e-mails contain information which we believe may be of interest, such as

the latest news on our products and services.

Information collected automatically by the Mobile Application.

The Mobile Application may automatically collect information about the User, such as:

the User's IP address, the date and time the User has used the Mobile Application, hardware

and software information, operating system information of the User's mobile device, including

language setting information.

Company Internal

The mobile application can access various services and data of the user's mobile device,

such as accessing photos, media files and other files on the mobile device, making and

processing phone calls, sending and viewing SMS messages, accessing the phone book and

camera of the mobile device User. In any case, such access is not granted without the consent

of the User.

Due to the fact that the operation of the Mobile Application is related to Vayosoft

equipment that is installed on the User's car, the Mobile Application may access information

about the User's car, for example: make, model, year of manufacture, engine volume, type

fuel, mileage, vehicle location and trip report, ignition status, engine condition, battery, vehicle

technical fluid level, detachment of equipment from the vehicle, geo-zones installed, driving

style, fuel consumption, technical No malfunction condition sensors car.

The purpose that the Mobile Application collects

and uses information about the User

The information collected through the Mobile Application is used for the following

purpose:

- to ensure the smooth operation of the Mobile Application;

- to enable the User to view the status of his car obtained with the installed equipment;

- for feedback and service from your car dealer / importer;

- to answer the User's questions;

- to provide the Customer with technical support services;

- to send administrative or marketing messages to the User;

- to detect and prevent fraud and misuse of the Mobile Application.

Getting access to

information about the User by the Company or third parties

The Company can work with third parties to develop and improve the Mobile

Application. These persons may collect statistical information about the use of the Mobile

Application and may only use information about the User to the extent necessary to provide

the Company or the User with the relevant services.

The Company shall grant access to: Yettel Ltd. Bulgaria, Yettel Ltd. Hungary and One Ltd.

Montenegro and Yettel Ltd. Serbia (in further text Yettel). Yettel will have access only to Users

information necessary for providing User support service.

For that purpose the Company shall enable access to the following information:

- User’s Vehicle information and other User information set out in the application by

User, such as User’s name, type of vehicle and phone number;

- Time stamp (date and time) of the latest status reported by Telematics device to the

server.

Section III

Rights of the User to protect personal data

In accordance with applicable data protection laws, you may have the following rights:

- request access to your personal data,

Company Internal

- request clarification of your personal data,

- request the deletion of your personal data,

- request a restriction on the processing of your personal data,

- request the ability to transfer data,

- object to the processing of your personal data,

- withdraw your consent and file complaints with supervisory authorities.

Right of access

You may be entitled to receive confirmation from us about whether we process

personal data related to you, and also, if appropriate, to request access to personal data.

Right to clarify

You may be entitled to receive from us clarification of inaccurate personal data related

to you. Depending on the purpose of the processing, you may be entitled to supplement

incomplete personal data, including by providing an additional application.

Right to delete (right to oblivion)

In certain circumstances, you may be entitled to request from us the deletion of your

personal data, which may oblige us to delete such personal data. In such cases, we will no

longer be able to provide you our services.

Right to restrict processing

In certain circumstances, you may be entitled to ask us to apply a restriction to the

processing of your personal data. In this case, the relevant data will be marked, and we will only

be able to process them for certain purposes.

Right to object and rights related to automated decision-making

In certain circumstances, you may be entitled, on the grounds related to your particular

situation, to object at any time to our processing of your personal data and to demand that we

no longer process your personal data.

In addition, if your personal data is processed based on our legitimate interests, you

have the right at any time to object to the processing of personal data related to you for such

purposes.

Right to data transfer

In certain circumstances, you may be entitled to receive your personal data that you

have provided to us in a structured, generally accepted and machine-readable format (i.e.

digitally) and you may be entitled to request the transfer of such data to another person

without any obstacles on our part if such a transfer is technically feasible.

The right to withdraw consent

In cases where the processing of your personal data is based on your consent, you can

withdraw your consent at any time free of charge and without providing us with any

explanation. Withdrawal of consent will not affect the legality of processing on the basis of

consent that took place prior to such withdrawal. If you withdraw your consent to the

processing of your personal data by us, we may not be able to provide you (in whole or in part)

with the services you request.

The right to file complaints with supervisory authorities

Company Internal

If you believe that there has been a violation of your rights to protect personal data, you

can also contact your local data protection authority to file a claim, in particular in a

participating country at your place of permanent residence, place of work or place of alleged

violation of rights

Section IV

Receiving and transferring personal data to third parties

The personal data of personal data subjects can be transferred to the following categories of

recipients:

- legal entities and individuals with whom we have contractual relationships based on

agreements concluded;

- to third parties to whom the personal data subject asks us to transfer their personal data or

about which the personal data subject is otherwise notified and agrees with this when

registering in the Mobile Application;

- legal entities with whom we plan to merge or takeover on the basis of documents accepted by

us as part of the merger or acquisition. In that case, we require that the new joint legal entity

comply with the requirements of this Policy regarding the processing of personal data;

- to state bodies or third parties in response to a request for information as part of an

investigation of illegal activities;

- to government authorities in order to comply with applicable law.

Technical information of user devices we can transfer to our partners.

Before we share personal information, we enter into written agreements with the

recipients which contain data protection terms that safeguard your data.

Service providers will only be permitted to obtain the personal data that they need to

deliver their service. We will not disclose personal data to third parties for the purpose of

allowing them to market their products or services to you. If you do not want us to share

personal data with these companies, please contact us by e-mail:

Section V

Transfer of personal data to third countries

The transfer of your personal data outside the European Economic Area may be

necessary to provide you with the requested service, and your personal data may become

available to data processors and service providers of countries that do not provide the level of

data protection that is supported on the territory of the European Economic Area. Therefore,

Vayosoft will take all necessary measures, if necessary, with respect to the recipients of your

personal data, if necessary to ensure an appropriate level of protection, as defined by the

applicable data protection law, in particular by applying standard contractual terms issued by

the European Commission or by the European Commission deciding whether that the country

in which the recipient of the transmitted data is located provides an appropriate level of data

protection.

If, when transferring data abroad, it is not possible to provide an adequate level of

protection for personal data, we will ask you to provide explicit consent for such data transfer

abroad. Keep in mind that such data transfers may be associated with certain risks, in

particular, in the country where the data recipient is located, unauthorized third parties may

also have access to these data, and you may not be able to exercise your rights of the data

subject, as well as his right to challenge actions that may harm your personal data and violate

your right to privacy.

Company Internal

Section VI

Security

The user is obliged to make sure that his / her information is correct and that the

account registration information is secure and is not disclosed to third parties.

Keep registration information in your accounts in a safe place and do not share it with

third parties. If you become aware of any unauthorized use of your account registration

information or other breach of security, please notify the Company immediately.

Note that none of the existing data transfer methods can be completely secure.

Therefore, a Company that cannot guarantee absolute security of information.

The Company is not responsible for the illegal actions of third parties, hackers, attackers

and other violators who may attempt to gain or use information about the User in whole or in

part for personal purposes.

The Company is not responsible for any actions or omissions of the User and third

parties regarding sharing the information about the User, regardless of whether this

information was shared through the use of the Mobile Application or otherwise.

Warning! The Company never stores any user passwords (which is why the Company

cannot recover lost passwords) and stores information on secure servers.

Section VII

Data deletion and storage period

The personal data of the person in question will be deleted or blocked as soon as the

purpose of storage ceases to apply. Furthermore, the data may be stored if this has been

provided for by the European or national legislator in EU regulations, laws or other provisions

to which the Personal Data Operator is subject. The data will also be blocked or deleted if a

storage period prescribed by the aforementioned standards expires, unless there is a need for

further storage of the data for the conclusion or fulfillment of a contract.

Section VIII

Automated decision in individual cases including profiling

You have the right not to be subject to a decision based exclusively on automated

processing - including profiling - that produces legal effect upon you or significantly impairs you

in a similar manner. This does not apply if the decision

- is necessary for the conclusion or performance of a contract between you and

Vayosoft;

- is allowed by the law of the Union or of the Member States to which Vayosoft is

subject, and that law contains the appropriate measures to safeguard your rights,

freedoms and legitimate interests, or

- takes place with your explicit consent.

However, these decisions may not be based on special categories of personal data

pursuant to Art. 9 para. 1 of the GDPR, unless Art. 9 para. 2 lit. (a) or (g) of the GDPR applies

and the appropriate measures have been taken to protect rights, freedoms and your legitimate

interests.

In the cases referred to in (1) and (3), Vayosoft shall take adequate measures to

safeguard rights, freedoms and your legitimate interests, including at least the right to obtain

the intervention of Vayosoft, to express one’s own point of view and to challenge decisions.

Company Internal

Section IX

Right of appeal to a supervisory body

Without prejudice to any other administrative or judicial remedy, you have the right to

file an appeal to a supervisory authority, in particular in the Member State where you reside,

work, or in the place of the suspected infringement, if you believe that the processing of your

personal data violates the GDPR or national Legislation.

The supervisory authority to which the complaint has been lodged will inform the

complainant of the status and results of consideration of the complaint, including the possibility

of a judicial remedy under Art. 78 of the GDPR.

Section X

Final provisions and contact information

The Company may modify its Privacy Policy and we therefore recommend that you

regularly review the Privacy Policy published on the Company's official website on the Internet

https://drivey.biz

Bulgarian, Hungarian, Montenegrin and Serbian language. If the provisions of the Privacy Policy

between the English language and its translation to other languages are inconsistent, the

For questions, comments, and queries regarding the Privacy Policy, you can contact

Customer Service at or email us at .