Privacy Policy

PLEASE READ CAREFULLY THIS DOCUMENT PRIOR TO USING OUR SERVICES.

1. Introduction

When you use the services of RideSafe Technology SRL, (hereinafter referred to as "RIDE SAFE"), you entrust us information about yourself, also known as personal data, by virtue of your confidence in us. We thank you for your confidence, that is why we want to clearly and transparently explain what are our practices regarding the privacy of your data. Through this policy, we point out what type of information we collect, the way in which we use it, as well as the options you have in relation to this data

2. Whom does this Privacy Policy apply to?

Summary: This policy applies to the worldwide users of RIDE SAFE services, including to the users of apps, websites or of any other functions offered by RIDE SAFE (hereinafter, taken as a whole, referred to as "RIDE SAFE platform" or "RIDE SAFE"). At the moment, we operate and function in Romania, but we intend to extend at global level, by offering our services. This policy describes the way in which RIDE SAFE and its affiliates collect and use the users' personal data (both customers as well as partners), in order to be able to provide the offered services. The policy applies to all who use the RIDE SAFE products in one way or another, as defined in the Terms and Conditions (we recommend you read them carefully prior to giving your consent), by means of the apps, websites or any other functions offered by RIDE SAFE. To better understand how it works, the policy applies especially to: • customers: users that register on RIDE SAFE and who require or benefit from services provided by RIDE SAFE, as defined in the Terms and Conditions; • partners: users that register on RIDE SAFE and who provide services to RIDE SAFE customers; RIDE SAFE works with a series of partners/persons in order to provide services (they are not publicly seen, but they help us provide our services to you) and which are connected to the services provided by RIDE SAFE (an example would be the hospitals/clinics we maintain direct contact with in order to improve the research and development part). Given that it would take us too long to list all these persons, as they keep on changing, all the persons indicated above shall be defined in this policy as "users" and these conditions shall apply to them.

3. Personal Data Operator

As you could or will see, RIDE SAFE requires certain personal data, according to the stage you are in on the RIDE SAFE platform. Because we decide on what type of information we request, according to the General Data Protection Regulation, we are a data operator. You can find our identification data below: c Denomination
Registered office
Phone no.:
E-mail
DPO Contact:
If there are unclear aspects, observations or if you have complaints regarding us or the personal data we process for you, you can send us an e-mail to the above address, as any moment.

4. Information We Collect

Summary: RIDE SAFE collects the following personal data:
• the information you provide to RIDE SAFE, for example, when you create your RIDE SAFE account;
• the information created when you use our services, such as medical history, location data, use of devices etc.;
• information obtained from other sources, such as from RIDE SAFE partners and third parties using RIDE SAFE's API keys or who have access to the platform.

4.1. Information You Provide
4.1.1 Information provided when you create your account:

Information necessary for registration When you register on RIDE SAFE, the following information is necessary to finalize the registration process and to create an account on our platform:
• e-mail address;
• last name;
• first name;
• phone number;
• password;
• profile photo.
Demographic Information Demographic information: we may collect demographic data about you, including through user surveys, for the improvement of our services. Content provided by you on various occasions We may collect information you send when you contact RIDE SAFE customer support, when you rate RIDE SAFE partners/other users or when you contact RIDE SAFE for any other reason (through the contact form on the platform, chat application, by phone etc.) Agenda or Calendar There are situations in which we may access the agenda or calendar associated to your e-mail address used for registration, in order to be able to schedule a meeting with one of RIDE SAFE partners for the provision of our services.

4.1.2 Information provided when you use our services:

They may include:
• Medical Information: in order to benefit from the RIDE SAFE platform services, you will be asked about your medical history, health issues, blood group, current or past medication, provision of medical imaging (X-rays, CT, MRI, tomography, positron emission tomography etc.)
• Information about Transactions: We collect details regarding the transactions related to the use of our services, including: type of services requested or provided, order specifics, time and date of service provision, collected amount and payment method.
• Usage Information We collect information on the way in which you use our services. It includes information such as the access dates and times, functions of the app or pages viewed, app errors and other system activities, browser type and third party websites or services you use prior to using our services. In some cases, we collect this information by means of cookies, tracking pixels and similar technologies which create and run unique identifiers. In order to find out more about these technologies, please access the Cookies Policy.
• Information about Devices: We may collect information about the devices you use to access our services, including the hardware designs, the device's IP address, operating systems and versions, software, file names and versions, preferred languages, the device's unique identifiers, marketing strategy identifiers, series numbers, information on the device's mechanism and information on the mobile network or internet.
• Location Information: We may collect information regarding your location, through the GPS installed on the device and through the connected functions (such as mobile/Wi-Fi data usage) in order to find your location within the purpose of being able to benefit from our services.
• Communication Data: In order to facilitate the provision of our services, we allow our users to communicate directly with the physicians/emergency services and with RIDE SAFE by means of the apps, websites and of other RIDE SAFE services. For example, we allow RIDE SAFE users to call or text each other through RIDE SAFE. In order to provide this service, RIDE SAFE receives some information regarding the calls or messages made through RIDE SAFE platform, including the date and time of the call/message and the information transfer's content. Likewise, RIDE SAFE may use this information for customer support services (including for the settlement of disputes between patients, physicians and partners), for safety and security services, for the improvement of our products and services and for analysis.

4.2. Information from Other Sources

For you to enjoy our services' experience, we may process information about you from other sources, as well, such as:
• user feedback, such as rating or assessment;
• financial services providers;
• sources available to the large audience;
• marketing services providers.

5. How do we use the obtained information?

RIDE SAFE collects this information so as to offer services requested by you on the platform, to improve the service provision, as well as for the development of new technologies to meet your needs.
More specific, we use the information:
• to improve our users' and our services' safety and security;
• for support offered to users;
• for research and development;
• to allow communication to or between users;
• in relation to legal procedures.
RIDE SAFE does not sell or share your personal information to third parties within the third parties' direct marketing purposes. RIDE SAFE does not process medical data within research, profiling or automated decision purposes. RIDE SAFE uses the information you provide, in order to:

5.1. provide the services and ensure functionality.

RIDE SAFE uses the collected information in order to provide, to customize, to maintain and to improve its products and services. This includes the use of information for the following:
• to create and to update your account;
• to confirm your identity;
• to allow access to the services provided by RIDE SAFE, according to the Terms and Conditions;
• to process or to facilitate the payment for these services;
• to activate the functions which allow you to send information to other persons, such as information exchange between users through the app (be it by text, video or voice);.
• to activate RIDE SAFE account customization functions, such as to allow fast access to the history, transactions and chat with the users on the RIDE SAFE platform;
• to carry out internal operations necessary to provide our services, including troubleshooting software and operational errors, data analysis, testing, study, monitoring and analysis of usage and activity trends.

5.2. Safety and Security

RIDE SAFE considers that our users' safety and security must come first, in order to deliver a high standard service. Consequently, we will use the information you provide us for the following:
• to verify the users and partners prior to allowing them to use our services and at subsequent intervals, including by analysing the verification of: (a) the eligibility conditions for the profession they belong to or (b) the history when the law allows it, in order to prevent the users or the partners that do not fulfil the legal requirements from using our services;
• our identity confirmation functions when accessing the platform ensure only the fact that the relevant identified user has access to the account attributed to that particular user, this protecting the user information and offering the security of the data which cannot be accessed by foreign persons;
• the use of the assessments provided by other users in order to remove, if the case, another user or partner from the platform. This assessment can be carried out through an automated decision-making process and the concerned persons are entitled to oppose to this process.

5.3. Customer Support

RIDE SAFE uses the information provided by you (such as the app history, interaction with other users, payment methods, cases entered through the platform, personal data etc.) in order to improve the support service offered to the users, such as for the following:
• to investigate and solve your problems;
• to monitor and to improve the answers you receive from the customer support;

5.4. Research and Development

RIDE SAFE is continuously improving the services it provides to the users, through continuous research and development of the solutions we want to implement, in order to constantly provide qualitative and competitive services and to facilitate access to information. That is why your data is very important for us and we will be able to use it for testing, research, analysis and development of products. This allows us to improve our services' safety and security, to develop new functions and products and to facilitate the provision and expansion of our services.

5.5. RIDE SAFE Messages

RIDE SAFE may use the information provided by you to send you messages regarding your order status, platform updates, events, newly entered services and similar.

5.6. Legal Procedures

We may use the information you provide to us so as to investigate or to settle disputes regarding the use of RIDE SAFE services or for any other purpose permitted by the applicable law. Likewise, RIDE SAFE could transmit the provided information in accordance with the requirements coming on behalf of the jurisdictional bodies having competence over the access to this information, such as criminal investigations, cases on the dockets of law courts or in preliminary proceedings etc.

6. Transfer of Obtained Information

RIDE SAFE considers that the user must know where the data he/she provides is transferred to. We work with partners and service providers we carefully select, in order to make sure that your data is safe throughout the period you enjoy our services.

6.1. Transfer to Other Users

If you are a user, we may transfer your personal data to physicians/speciality personnel/emergency services or to other commercial partners so as to fulfil our service. This data shall refer, without limitation, to: last name, first name, profile photo, contact data, location, medical history, medical analyses (i.e. image-supported or in other electronic format), age, blood group etc.

6.2. Transfer to Service Providers and RIDE SAFE Partners

RIDE SAFE may transmit information to the service providers and to its partners within research and development, marketing, invoicing purposes etc., such as:
• payment processing and facilitation partners;
• invoicing and book-keeping partners;
• cloud storage services providers;
• marketing partners and marketing platform providers;
• data analysis service providers;
• research and development partners, including the ones conducting surveys or research projects in collaboration with RIDE SAFE or on behalf of RIDE SAFE;
• providers helping RIDE SAFE to improve the apps safety and security;
• specialists, lawyers, accountants and other professional service providers.
If you are a user, we may transfer your personal data to the research and development partners (i.e. partner clinics, hospitals, research and development centres), anonymously or under a pseudonym, in order to contribute to the improvement and expansion of the provided services, according to section 5.4.

6.3. Transfer of Data to Competent Authorities

RIDE SAFE may transfer the data obtained from you to the competent authorities and bodies in the case of a legal proceeding or of a dispute referring to the RIDE SAFE services, when requested in accordance with the applicable legislation, at their request.

7. Data Preservation

According to the regulations in force, we do not want to keep the data more than necessary, as a measure for protecting the private life. RIDE SAFE keeps the information referring to the user profile and other information throughout the entire period of RIDE SAFE account's activity. RIDE SAFE keeps the information referring to transactions and usage statistics for 5 years, due to the regulations, tax and insurance requirements, as well as to other requirements in force where it operates . After this period expires, RIDE SAFE deletes or passes under anonymity such information in accordance with the applicable laws. RIDE SAFE keeps medical information (i.e. analyses provided by the user, medical history etc.) throughout the entire period of RIDE SAFE account's existence. After this period, in case the account is deleted, RIDE SAFE can continue to keep the obtained data, after the data is rendered anonymous, so as to use it within statistical purposes, for research, development, expansion and improvement of the provided services. The users may request the deletion of the account at any moment. Following such a request, RIDE SAFE will delete the information which no longer must be kept and it will restrict the access or the use of any information which still must be kept, in accordance with what was indicated above.

8. Data Storage

The personal data you provided to us and which we process are processed within the EEA ("European Economic Area") and stored in the Amazon Web Services (in Europe). Nevertheless, this data can be processed by the personnel outside EEA working for us or for one of our business partners or service providers. An exhaustive list of the sub-authorised third parties and details about their privacy policies will be found on our website, when they exist. Some countries outside EEA cannot ensure the same adequate protection level for your rights and liberties with reference to the personal data processing; nevertheless, by using our services, you give your consent for RIDE SAFE to present personal data to those third parties. Please contact us using the data provided under section 3 for more details regarding the specific guarantees applied to the transfer of your personal information outside EEA.

9. Purpose of Processing

RIDE SAFE uses the information you provide to give you access to the services you access through the platform. For the good fulfilment of these services, RIDE SAFE shall use the provided information in other purposes, as well, such as for invoicing, statistics, research & development etc. If RIDE SAFE considers that the provided information could also be used within other purposes than the ones listed above, it will immediately inform the users on the matter.

9.1. Data processing is necessary for the provision of the services you request

RIDE SAFE must collect and use certain information for the provision of services. It includes:
• information on the user profile necessary to create and maintain the account, including to confirm identity, to establish communication with the other users and to be able to make or receive the payments;
• information on the verification of the legal conditions fulfilment and on the history, necessary to allow the trade partners to provide the services through RIDE SAFE platform;
• information on the transactions and cases entered on the platform which must be generated and preserved, in relation to the way in which you use the RIDE SAFE services;
• information on the use of RIDE SAFE services, necessary to maintain, optimize and improve RIDE SAFE services.

9.2. Processing is necessary for RIDE SAFE's legitimate interests

RIDE SAFE collects and uses personal information to the extent in which this is necessary for the fulfilment of its legitimate interests. This includes the collection and use of the information:
• to maintain and improve the user safety and security;
• to prevent, detect and to fight the fraud that could be connected to the use of our services;
• to provide user support services;
• to optimize the provided service and to develop new services;
• within research, development and analysis purposes (usage trends analysis included in order to improve user experience and to offer new services);
• to determine the direct marketing strategy (the users' usage trends analysis is included, in order to offer marketing campaigns adapted to needs);
• to meet the RIDE SAFE terms & conditions.

9.3. Processing is necessary to meet RIDE SAFE's legal obligations

RIDE SAFE is subjected to the applicable law having jurisdiction over the territory in which it operates. To this purpose, there will be situations in which RIDE SAFE would transmit your personal data to the competent bodies when asked for such data, for the settlement or prevention of disputes.

10. Grounds for Processing

RIDE SAFE is based on your consent when processing your personal data. We do not want to process the personal data of people aged under 16, that is why we will carry out verifications to this respect and we will ask for the consent of the parental authority holder in the event the concerned person shall be a minor under 16 years old. You can withdraw your consent at any moment. If you withdraw your consent, you will no longer be able to use the services or functions that require the collection or use of the information we obtained or used based on your consent. Likewise, RIDE SAFE uses various grounds for processing the data you provide in order to be able to offer the platform services. They are as follows: Data element Grounds for processing Last name, first name, e-mail address, telephone number Article 6 para (1) letter b GDPR – to fulfil the contract you remotely conclude with us when you create an account on the platform and when you access our services Invoicing data Article 6 para (1) letter b GDPR – to fulfil a legal obligation provided by the applicable legislation Medical information (date of birth, gender, analyses - including image-supported, medical history, treatment, symptoms, anamnesis, potential causes for the symptoms etc.) Article 9 para (2) letter a) GDPR - explicit consent – health data are part of a special data category for which the concerned person's express consent is needed. Article 9 para (2) letter j GDPR - scientific research purposes or statistical purposes – RIDE SAFE is constantly aiming at improving the offered services, by discovering new processes meant to help the medical field. To the extent in which, according to the geographical area, the user is aged under 16, we will request the consent of the parental authority holder, in order to provide access to our services. Location data Article 6 para (1) letter b GDPR – to fulfil the contract you remotely conclude with us when you create an account on the platform and when you access our services Promotional & marketing activities Article 6 para (1) letter a) GDPR – consent – in case of direct marketing, if you do not want to receive information and newsletters regarding our activity and provided services, you can withdraw your consent at any moment. Article 6 para (1) letter f) GDPR – legitimate interest – to promote the offered services and products, you can withdraw your consent at any moment. Data regarding credit cards, user information exchange etc. Article 6 para (1) letter f) GDPR – legitimate interest – we could use this data and other similar data to improve the offered services, to finalize the transaction process, to identify and to solve the users' problems etc.

11. Your Rights

Based on GDPR, you have a series of rights regarding your personal data: Access Right You have the right to request information on the personal data we process and which concern you. We will try, to the possible extent, to offer you the information regarding your data in a machine-readable manner as clear, accessible and structured as possible. In order to do so, we must make sure that the relevant data refer to you, therefore we will identify you based on a copy of your ID you provide us. Data Correction Right Your data should be permanently up-to-date and complete. Even though we make all the efforts to make sure your data is always correct, we will also need your help. If you discover that your data is not correct, that changes occurred or if you want to add something, please send us a request for the correction of that data, be it an update, amendment or supplementation. Right to Cancellation/Right ”to be forgotten” You can ask us to delete your personal data in the following cases:
• the personal data is no longer necessary for the fulfilment of the purposes for which it was collected or processed;
• you withdraw your consent based on which the processing takes place;
• You oppose data processing when such personal data processing has direct marketing as purpose;
• personal data was illegally processed;
• personal data must be deleted so as to comply with a legal obligation.
The users may request the deletion of the account at any moment. Following such a request, RIDE SAFE will delete the information which no longer must be kept and it will restrict the access or the use of any information which still must be kept, in accordance with what was indicated under section 7. Right to Limit Processing You can ask us to limit your personal data processing in the following cases: • you challenge the exactness of your personal data, but for a period allowing us to check the exactness of your data;
• data processing is illegal and you do not agree with the deletion of your personal data, but you request in exchange to limit its processing;
• we no longer need your personal data, but you request it to ascertain, exercise or defend a right in court;
• you oppose your personal data processing when the personal data processing has direct marketing as purpose, for the time period in which verifications are carried out to see if our legitimate rights prevail over yours.
Right to Data Portability You can ask us to send the personal data concerning you and that you provided to us in a structured form, currently used and automatically-readable and you have the right to transmit such data to a different operator, under the following circumstances:

• data processing is based on consent;
• data processing is carried out through automated means.
Right to Oppose You have the right to oppose processing when: (a) processing is needed to fulfil a task which serves for a public interest, (b) processing is necessary within the legitimate interests followed by us or by a third party, including for the creation of profiles based on the relevant provisions. In such cases, we no longer process your personal data, except for the case when we prove we have legitimate and imperative reasons that justify data processing and which prevail over the interests, rights and liberties of the concerned person or when the purpose is to ascertain, exercise or defend a right in court. The right to oppose an individual automated decision-making process, including the creation of profiles You have the right to not be the object of a decision exclusively based on automated processing, including the creation of profiles who produce legal effects concerning you or which affect you in a similar way, to a significant extent. Such right has certain limitations, i.e.: • the automated decision is necessary to conclude or to carry out a contract between you and us; • the decision is authorised according to the legal provisions; • we have your explicit consent for this matter. In such a case, please send us a request for us to subject your personal data to a manual processing process.

12. Complaints

If you believe that an issue with the personal data processing occurs, please send us first a request to the address indicated under section 3 (dpo@ridesafe.ro) – we will make all the efforts to settle amicably your request within the shortest time possible. Likewise, you may submit a complaint to the supervisory authority for personal data. For Romania, the contact data can be found below: Name National Supervisory Authority for Personal Data Processing Address B-dul G-ral. Gheorghe Magheru nr. 28-30, Sector 1, zip code 010336, Bucharest, Romania Phone no.: +40.318.059.211 or +40.318.059.212 E-mail anspdcp@dataprotection.ro

13. Changes to This Policy

We may occasionally update this policy and we will notify you through the RIDE SAFE platform or by e-mail regarding the most recent version. Even if you do not get a notification, we encourage you to access and to read periodically this policy in order to be up-to-date with its most recent versions.