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Privacy Policy (EU Version)

Last updated: 14-Nov-2025

Effective date: 19-Nov-2025

Applies to: Users located in the European Economic Area (EEA)

1. Introduction

This Privacy Policy explains how Autoware Lab Ltd (“we”, “us”, “our”) collects, uses, stores, and protects personal your data when you use the Next Europe mobile application (“the App”).

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We are committed to protecting your privacy in accordance with:

  • the General Data Protection Regulation (EU) 2016/679 (“GDPR”),

  • applicable EU and member state privacy laws,

2. Data Controller

Autoware Lab Ltd

Address: Ahinora building, NPZ Dianabad, ul. "Tintyava" 15-17, 1113 Sofia, Bulgaria

Email: license@autowarelab.com

Website: https://www.autowarelab.com

3. Personal Data We Collect

We only collect data that is necessary for the App’s core functionality. The data we collect falls into the following categories:

3.1. Data Provided Directly by You

  • Account Information: email address, password (stored hashed), display name.

  • Vehicle Credentials / Tokens (where applicable): stored securely and encrypted.

3.2. Automatically Collected Data

  • Identifiers

    • Device instance ID (for analytics and crash reporting)

    • App user ID

  • Location Data

    • Background phone location — required for features such as geofencing or nearby-vehicle services

  • Diagnostics

    • Crash logs

    • Performance metrics

    • Error reports

  • Usage Data

    • Interaction events

    • Features used

    • App configuration data

3.3. Vehicle-Related Data (if applicable)

Depending on your connected vehicle brand/model and features you choose to use:

  • Vehicle Identification Number (VIN)

  • Vehicle telemetry

    • Vehicle status information (e.g. Odometer readings, Charging level)

    • Precise vehicle GPS location

    • Trip summaries

    • Remote command execution history

  • Other OEM-provided telemetry

 

This data is only collected when the user has explicitly connected their vehicle account

and only for the purpose of providing the vehicle-related features of the App.

4. Permissions and Why We Request Them

We request certain OS-level permissions.

4.1. Background Location

Used to:

  • Show your current location relative to the vehicle (“Find My Car”)

  • Provide geofence-based vehicle features

  • Improve navigation-related functionality

 

We do not use location for advertising or tracking.

4.2. Push Notifications

Used for:

  • Vehicle alerts (locking, alarms, charging state, etc.)

  • Remote command confirmations

  • System messages

  • Account or security alerts

4.3. Bluetooth / Connectivity

Used to connect to accessories or vehicle devices (if supported).

4.4. Camera / Photo Access

Used only for optional features (uploading profile image, etc.).

Not required for core functionality.

We do not collect microphone data or any sensory data not explicitly required.

5. How We Use Your Personal Data

We use personal data solely for the purposes listed below:

5.1. To Provide Core App Functionality

  • Connecting to your vehicle

  • Displaying vehicle status

  • Executing remote commands

  • Trip recording and statistics

  • ​Location-based features

5.2. Account and Security

  • Authentication

  • Fraud prevention

  • Secure storage of tokens

  • Account management

5.3. Service Improvement

  • Debugging, diagnostics, and crash reporting

  • Usage statistics to improve reliability

  • Sharing anonymized data with third parties for further development

5.4. Legal Compliance

  • Responding to lawful requests

  • Maintaining records required by EU law

6. Tracking

We do not track you across apps or websites,

and we do not use data for:

  • targeted advertising

  • cross-app profiling

  • third-party marketing

Therefore, the App does not request App Tracking Transparency (“Allow Tracking?”) permission.

7. Legal Basis for Processing (GDPR Art. 6)

We process your data based on:

  • Contract performance — providing vehicle and account features

  • Legitimate interest — app security, analytics, fraud prevention, service improvement

  • Consent — location, notifications, Bluetooth, optional features

  • Legal obligation — record-keeping, security-related compliance

 

You may withdraw consent at any time in the App settings or device settings.

8. Data Sharing

We only share personal data with trusted processors who comply with GDPR.

8.1. Service Providers

Examples:

* Servers are hosted and operated by Autoware Lab Ltd, if necessary compliant external service providers

might be used.  All providers are bound by strict data-processing agreements (DPAs).

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We do not share:

  • personal data with advertisers

  • data with third-party analytics for profiling

  • data with data brokers

  • health or sensitive data with third parties

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9. International Data Transfers

If data is transferred outside the EU, it is protected using:

  • Standard Contractual Clauses (SCCs), OR

  • ​GDPR-compliant Data Processing practices by the service providers

10. Data Retention

We retain data only for as long as necessary:

  • Account information — until account deletion

  • Vehicle data — until removed by user or account is deleted

  • Vehicle logs — automatically deleted after processing

  • Vehicle trips data — stored only as long as needed for displaying vehicle trips history

  • Crash logs & diagnostics — 30-90 days depending on provider

  • Backups — retained on encrypted systems for up to 90 days

  • Legal records — up to 5 years (statutory requirement)

  • You may request earlier deletion (see Section 12).

11. Account Deletion

You may delete your account directly inside the App:

App → Settings → Account → Delete Account

Upon deletion:

  • ​All personal data associated with your account is erased

  • Vehicle tokens and credentials are revoked

  • Trip data, logs and history are deleted

  • Backups are deleted after their automatic retention window

  • Some records may be retained only where legally required

12. Your Rights Under GDPR

You may exercise the following rights anytime:

  • Right of access (Art. 15)

  • Right to rectification (Art. 16)

  • Right to erasure (Art. 17)

  • Right to restriction (Art. 18)

  • Right to data portability (Art. 20)

  • Right to object (Art. 21)

  • Right to withdraw consent (Art. 7)

 

We will respond within 30 days. Requests can be made via:

license@autowarelab.com

13. Children’s Privacy

The app is not intended for children under 18, and we do not knowingly collect data from them.

If we discover that data from a minor has been collected:

  • We will delete it immediately

  • We will disable the account

14. Security

14.1. Data security

We apply industry-standard security measures:

  • Encryption in transit (TLS 1.2+/HTTPS)

  • Encryption at rest

  • Secure key management

  • Limited-access internal systems

  • Two-factor authentication for staff access

  • Regular security audits

 

No method of transmission is 100% secure, but we take all appropriate steps to protect your data.

14.2. Vehicle commands security

We have “protected” vehicle commands (lock/unlock) which require authentication. This is achieved through the phone security mechanisms (e.g. biometric authentication, PIN).

15. Changes to This Policy

If we make material changes:

  • We will notify you in the App and/or by email

  • You may review the updated policy before continuing use

16. Contact Us

For any questions or concerns:

Autoware Lab Ltd

Address: Ahinora building, NPZ Dianabad, ul. "Tintyava" 15-17, 1113 Sofia, Bulgaria

Email: license@autowarelab.com

Website: https://www.autowarelab.com

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