Privacy Notice for Drivers

This notice is information provided under Art. 13 and 14 GDPR and under Directive (EU) 2024/2831 on improving working conditions in platform work. It is not a consent and does not require your acceptance.

The contractual counterpart to this notice is Part C of the Platform Terms of Use (nutzungsbedingungen). Where this notice refers to a clause such as "C2", it means a clause of Part C.

1. Controller and Data Protection Requests

Controller within the meaning of the General Data Protection Regulation (GDPR) for the processing described in this notice:

Emaride EU S.à r.l. société à responsabilité limitée under Luxembourg law represented by its sole manager Ramez Mohamad Alkhalaf Luxembourg [Placeholder: address to follow] Trade register (RCS): registration pending VAT (TVA): registration pending Email: info@emaride.lu

Data protection requests: privacy@emaride.lu

A data protection officer has not been appointed at present. Assessing whether an appointment is required under Art. 37 GDPR, and the appointment itself, are open items before go-live. Until then, privacy@emaride.lu is the responsible point of contact.

Your fleet partner is a separate controller

You access the Platform exclusively through a fleet partner approved by Emaride (clause C0). Your employment or engagement relationship is with that fleet partner, not with Emaride.

For the data your fleet partner processes as your employer or principal — personnel file, employment contract, shift and duty planning, payroll, social security, working-time records — the fleet partner is itself the controller within the meaning of Art. 4(7) GDPR, not a processor of Emaride. Emaride gives it no instructions in that regard and cannot provide you with information about that processing.

This notice describes only the processing carried out by Emaride — that is, what happens via the Platform and the driver app. For everything else, please contact your fleet partner; under clause 15.3 of the Fleet Partner Agreement it is obliged to provide you with the transparency required by Art. 22 GDPR and Directive (EU) 2024/2831. On request we will name the contact point we hold on file for your fleet partner.

2. Categories of Data Processed

You do not see passengers' full payment card data and we do not store it; it is held exclusively by the payment provider (Section 7).

We do not process special categories of personal data (Art. 9 GDPR), such as health data. Proof of medical fitness to drive is not collected via the Platform; where your law requires such proof, it is held by your fleet partner.

3. Purposes and Legal Bases

Notifications are strictly transactional — ride offers, ride status, document reminders, penalty and support events. We do not send advertising or marketing messages to drivers, and there is no consent mechanism because there is nothing for which consent would have to be obtained.

4. No Processing Based on Consent

None of the processing listed in Section 3 relies on your consent. This is deliberate: in a relationship with a structural imbalance of power, consent would regularly not be freely given within the meaning of Art. 4(11) GDPR. The exception is the permissions you grant on your own device and can withdraw at any time — location access and push notifications (Section 6).

5. Automated Monitoring and Decision-Making

This section implements Art. 7 to 11 of Directive (EU) 2024/2831 and Art. 13(2)(f) and Art. 22 GDPR. It names every automated system that may significantly affect you, the categories of data that feed into it, the criteria and their weighting, and the consequences.

5.1 Ride assignment (dispatch)

When a passenger books a ride, the system automatically selects a driver and offers the ride to them. The process is entirely rule-based; there is no learning model and no profile about you.

Step 1 — pool of candidates (hard filters, no ranking). Only drivers enter the selection who

• are assigned to the fleet partner serving the zone of the pickup address,
• are registered in the country of the ride,
• have the status online in the app, and
• have no active ride (a driver may only have one ride at a time).

If you do not meet one of these points you will not receive the offer, regardless of all other criteria.

Step 2 — order (ranking criteria and weighting). A ranking is formed from the pool of candidates. Each criterion is converted to a value between 0 and 1 and summed into a score with the following weight:

Where scores are equal, the driver with the shorter distance receives the offer first. There are no other criteria: not your working time, not the number of rides you have completed, not your penalties, not your revenue, not your response time, not the amount of the fare.

Two limitations regarding distance which we disclose because they change your ranking:

• The distance criterion can be switched off and is currently off by default. When it is off, the distance value is identical for all candidates and the order results in practice from your average rating alone.
• If your stored position is older than four minutes (for example because the app had no connection), your distance counts as unknown and is treated as "very far". You will then be at the back of the ranking. Keep the app active while you are online if you want to receive offers.

Consequences. The assignment decides which ride is offered to you — not whether you accept it. If you decline or do not respond, the ride goes to the next driver in the ranking. If no driver is found, the booking is cancelled by the system and fully refunded to the passenger. The assignment is not a decision with legal or similarly significant effect within the meaning of Art. 22 GDPR, because it concerns a single offer and does not restrict your access. You may nevertheless object to the ranking and request a review (Section 5.6).

Automatic acceptance (driver setting). The driver app has a setting called "Automatically accept rides". When it is switched on and you have online status, the app confirms an incoming offer on its own, without you tapping anything. The setting is switched on by default and can be switched off at any time in the profile of the driver app; the change takes effect immediately and only for you. The setting does not feed into any ranking criterion: whether it is on or off changes neither your position in the ranking nor the number of offers you receive. The selection under Step 1 and Step 2 runs unchanged; the setting only takes effect afterwards, and only on your device.

What this changes for you. An automatically accepted offer is an accepted ride. If you are then unable to drive it, the way out is a cancellation — and a cancellation, unlike a decline, is on the penalty ladder (Section 5.2). If you do not want this, switch the setting off; you will then keep the offer with an acceptance window, the lapse of which has no consequences for you (Section 5.7).

5.2 Penalty levels

Certain events are automatically recorded as a violation and assigned to one of four levels: warning → warning with fine → suspension → permanent exclusion.

Data that feeds in: the type of event (declining an offer, cancellation by you, no-show, conduct complaint), the ride event, and the number of comparable violations within a rolling window of 30 days. No other data feeds in.

Rule and consequences:

• With no prior violation in the window: warning — no further consequence.
• First repeat: warning with fine. Amounts are uniform across markets and are offset against the payout to your fleet partner: cancellation €15, no-show €25, conduct €50. For declining an offer the amount is €0. Whether and how the fleet partner passes the amount on to you is governed solely by the contract between you and them (clause C0.2).
• Second repeat: suspension — app access is put on hold.
• Third and every further repeat: permanent exclusion.
• The counter expires after 30 days; a resolved penalty resets it.

Declining an offer is excluded from this ladder. It is logged but always remains at the "warning" level, never triggers a fine and never leads to suspension or exclusion (Section 5.7).

Human review. Suspension and exclusion are measures with significant effect and are not taken solely on an automated basis: permanent exclusion only takes effect after a responsible person at Emaride has expressly confirmed it following a review. Before that confirmation you can lodge an appeal in the app and state your reasons; your reasoning is stored with the penalty and forms part of the review. Every level is communicated to you with reasons.

5.3 Automatic lock on an expired record (auto-lock)

If one of your mandatory records expires or is rejected, a daily automated run sets your driver status to locked; you then cannot go online. An expired vehicle-related record correspondingly deactivates the vehicle.

Data that feeds in: exclusively the document type, review status and expiry date of the stored record. Neither ratings nor ride counts nor penalties play any role.

Advance warning: before expiry we automatically remind you and your fleet partner — 60, 30 and 7 days beforehand.

Consequences and lifting. The lock is a legally bound consequence of the expiry of a record and not an assessment of you as a person (clause C3.3). It is communicated to you with reasons. You may dispute the accuracy of the underlying data and request a review by a person. Once a valid record has been submitted, access is restored.

5.4 Ratings, mandatory trainings and fraud prevention

• Ratings are automatically aggregated from passenger stars into an average and a count. The average takes effect solely through the weight of 0.3 in the ranking under Section 5.1. A rating does not automatically lead to a lock, a fine or a penalty.
• Mandatory trainings: if an assigned training is overdue, an automated run sets the training assignment to "locked". This affects the training, not your app access; you can still take the test.
• Fraud prevention and login protection evaluate login attempts and ride patterns to detect abuse and account takeovers. If this results in a restriction of your access, the rights under Section 5.6 and clause C6 apply.

5.5 What is not decided automatically

The following in particular are not decided automatically: the amount of the fare (it follows the tariff set for the country, not your behaviour), your remuneration (it is governed solely by your contract with your fleet partner — there is no remuneration relationship between Emaride and you, clause C0.2), your working time and shifts, and the assignment of mandatory trainings.

5.6 Human review, expressing your view and contestation (Art. 22 GDPR)

For every decision with legal or similarly significant effect — in particular suspension, exclusion and locking of app access — you have the right:

• to human intervention and review by a person at Emaride,
• to express your point of view,
• to obtain an explanation of the decision and the circumstances on which it is based, and
• to contest the decision.

You can reach us via support in the driver app, at info@emaride.lu, or for data protection matters at privacy@emaride.lu. An appeal is reviewed by a person, not by a system. You may additionally contact your fleet partner; under clause 15.3 of the Fleet Partner Agreement it is obliged to support you in doing so.

Where there is an immediate risk to safety, in cases of fraud, on sanctions-related grounds, or upon expiry of a required official authorisation, a measure may take effect immediately; the reasons are then provided without delay and the review takes place afterwards (clause C6.3).

5.7 No sanction for not accepting rides

You decide freely whether to accept, decline or ignore a ride offer. Emaride provides for no sanction, no fee and no disadvantage for not accepting (clause C2.1). In concrete terms, for the systems described in this section this means:

• The acceptance rate is applied in the assignment model with a weight of 0 and is therefore expressly not taken into account — declining does not worsen your ranking and does not lead to fewer offers.
• In the penalty ladder, declining always remains at the "warning" level, triggers no fine (amount €0) and can never lead to suspension or exclusion.
• Your online/offline status, your availability and your working time feed into none of the described systems as an assessment criterion.

The fact that a decline is logged at all serves solely to make the course of the ride traceable (who received an offer and when) and to re-dispatch to the next driver. We disclose this rather than conceal it — it is not a basis for any measure against you.

This assurance applies to not accepting, not to cancelling. If you have switched on the "Automatically accept rides" setting (Section 5.1), the app accepts the offer on your behalf — a case of not accepting no longer exists. A subsequent cancellation is a cancellation and is treated as one (Section 5.2). The setting can be switched off at any time; with the setting switched off, this section applies unchanged.

5.8 Processing that is expressly excluded

Pursuant to Art. 7(2) of Directive (EU) 2024/2831 we expressly state that Emaride processes no data

• to predict or assess the exercise of fundamental rights, including the right to freedom of association, the right to strike and the right to collective bargaining,
• about your trade-union activity or your membership of a trade union or workers' representation body,
• about your private conversations and communications, including conversations with workers' representatives,
• about your emotional or psychological state,
• about your racial or ethnic origin, your migration or residence status, your political opinion, your religious or philosophical belief, your disability, your state of health including chronic illness, your sex life or your sexual orientation,
• about you outside your shift: when you are offline in the app, your position is neither collected nor stored (Section 6).

There is no profiling for advertising purposes. There is no biometric monitoring, no evaluation of camera or microphone data, and no emotion recognition.

5.9 Blocklist (registration bar after exclusion)

The blocklist (Section 3) prevents an excluded person from creating a new account in any role — including as a driver. Placing someone on the blocklist is decided by a person at Emaride, who records the reasons in writing. What happens at a later registration attempt is the enforcement of that earlier decision, not its formation. If only a name matches, nothing is decided at all — the case is referred to a person for review. If you believe a refusal was made in error, contact privacy@emaride.lu; we will review the case personally.

6. Location Data in Detail

The driver app processes your position only while you are online in the app. If you go offline, collection stops.

• During an active ride your position is transmitted to the passenger's app roughly every 5 seconds so that they can see the vehicle approaching. This transmission is direct and is not stored as a history.
• Only your last position is stored — throttled, as a rule at most every 30 seconds and only after movement of at least 50 metres, plus a heartbeat roughly every 90 seconds. This produces no movement history: each new position overwrites the previous one.
• This last position serves ride assignment (Section 5.1), the display in your fleet partner's fleet overview, and safety.
• You can withdraw location permission at any time in your device settings. Without location permission you cannot perform rides because the pickup cannot be coordinated; it is therefore a prerequisite for going online, not for your account.
• Background collection takes place only insofar as you permit it on your device, and only while you are online.

7. Recipients and Processors

Your fleet partner

Your fleet partner receives the data it needs for dispatching and to fulfil its obligations as your employer or principal — your master data, the status of your records, the vehicle assignment, your rides and settlements, your penalties and trainings, and your live position in the fleet overview. It is a separate controller for that purpose (Section 1), not a processor; the transfer is a controller-to-controller transfer under Art. 6(1)(b) and (f) GDPR and not processing on our behalf under Art. 28 GDPR.

The passenger

During a ride, the passenger sees your first name, your average rating, the vehicle (category, colour, licence plate) and your live position. Nothing else — in particular no contact details, no address, no documents and no bank details.

Further recipients

• Authorities — where legally required.
• Emaride staff and mandated reviewers — limited by role and country, for admission, support, compliance and the reviews under Section 5.6.

Processors (Art. 28 GDPR)

Emaride itself does not hold or control any Fare funds; cashless card payments are processed exclusively through Stripe as a licensed payment provider and merchant of record. You receive your remuneration from your fleet partner.

Not all listed services are currently in use. Twilio, Apple and Google are marked "not currently in use" above: phone login by SMS is switched off and has been removed from the app, and signing in with an Apple or Google account is not enabled. No personal data is currently processed through these three services. They remain in the table because they are technically provided for; if we put one of them into operation, that applies from that point and not retroactively.

The "Basis" column describes the contractual requirement for each processor engaged, not the status currently achieved: for processing within the EU, a data processing agreement (DPA) under Art. 28 GDPR is envisaged, and for transfers to third countries, EU Standard Contractual Clauses (SCC) under Chapter V GDPR are additionally envisaged. Concluding these agreements with the respective providers is a prerequisite for the Platform going live.

8. International Transfers

Insofar as data is transferred to countries outside the EEA (see the "Location" column in Section 7), this only takes place on the basis of appropriate safeguards under Chapter V GDPR, in particular the EU Standard Contractual Clauses or an adequacy decision of the EU Commission. The data itself is stored in the EU (Frankfurt).

9. Retention Periods

Deletion of the verification documents 24 months after offboarding runs automatically every day and expressly includes the file itself, not just the reference to it. The period is deliberately calculated slightly conservatively (24 × 30 days) so that it never applies too late.

Ride data is handled in two stages. After 24 months we irreversibly remove the metre-accurate GPS coordinates of a ride — that is the intrusive part and it has no tax function. The pickup and destination address, by contrast, is retained for 10 years: the invoice data contains no address, so the address of the ride is the only description of the service billed.

For penalties, trainings and your bank details we expressly promise no automatic deletion period, because none is implemented in the product. This data is retained for the duration of your admission and is deleted or anonymised on request (privacy@emaride.lu). Settlement data subject to statutory retention is preserved in the form required by law. We do not carry out automatic deletion for inactivity.

Retention hold in the event of litigation or a request from an authority. Where litigation, a request from an authority or other legal proceedings concern you personally, an authorised person at Emaride can suspend the automatic deletion of the following data: your verification documents including the file, the GPS coordinates of your rides, your last stored live position, the support tickets you opened and the chat content you wrote, notifications to you, and log data on operations you carried out (legal basis: Art. 6(1)(c) or (f) GDPR). If such a hold exists for the passenger of a ride, the GPS coordinates of that ride are retained as well. The data is then stored beyond the period stated above until the hold is lifted, and is removed by the next deletion run thereafter. There is no such hold for your other data in this section.

10. Your Rights

Under the GDPR you have the right to:

• access (Art. 15),
• rectification (Art. 16),
• erasure / anonymisation (Art. 17),
• restriction of processing (Art. 18),
• data portability (Art. 20),
• object to processing based on legitimate interests (Art. 21),
• the rights under Art. 22 in relation to automated decisions (Section 5.6).

For the right of access under Art. 15 we provide a data export in the app: you trigger it yourself and receive a file containing your master data, your bank details, your rides and settlements, your penalties including any appeal, your trainings, and time-limited links to your stored documents. For ratings, the export contains the star aggregate (average and count) rather than the individual ratings — otherwise the ratings would be attributable to individual passengers, whose statements are confidential towards you. The export file is deleted after 8 days and the download link is valid for 7 days.

For anything else, please contact privacy@emaride.lu. We respond within one month (extendable under Art. 12(3) GDPR).

11. Right to Lodge a Complaint with the Supervisory Authority

You have the right to lodge a complaint with a data protection supervisory authority. The competent authority in Luxembourg is the

Commission nationale pour la protection des données (CNPD) 15, Boulevard du Jazz, L-4370 Belvaux, Luxembourg <https://cnpd.public.lu>

As the controller is established in Luxembourg, the CNPD is the lead supervisory authority (one-stop shop, Art. 56 GDPR). Data subjects resident in Germany may in addition contact their competent regional data protection authority (Landesdatenschutzbehörde) at any time (Art. 77 GDPR). Complaints about your fleet partner as a separate controller should be addressed to the authority competent for it.

12. Data Security

We implement appropriate technical and organisational measures (including encryption in transit, access controls by role and country, hashed passwords, separate storage of document files with time-limited access links) to protect your data (Art. 32 GDPR).

13. Changes to This Notice

We may adapt this notice to reflect changes in the law or in functionality. If an automated system described in Section 5 changes — in particular the criteria or their weighting — this notice will be updated with a new version. The current version is available in the app and on the website; it carries a version number and an effective date.

14. Deviations from the V2.1 Legal Package

This notice follows the GDPR Compliance Package Part B. Where it deviates, this is because it may only describe what the product actually does: