# PRIVACY POLICY – FOX TRANSFER DRIVER APP **Version:** 1.2.0 **Effective Date:** 20/01/2026 ## 1. WHO WE ARE This Privacy Policy explains how Fox Transfer Brasil Serviço de Receptivo Ltda. ("we", "us", "our") processes personal data when you use the Fox Transfer Driver App. **Data Controller** Fox Transfer Brasil Serviço de Receptivo Ltda. Rua Carlo Prina, 52 – Brooklin – São Paulo – Brasil – 04601-030 Telephone: +55 11 3995 6797 (Brasil) WhatsApp: +55 11 94392 7348 Website: http://www.foxtransfer.com.br Email: info@foxtransfer.com.br Company Registration No (CNPJ): 21.727.286/0001-81 ## 2. PERSONAL DATA WE COLLECT We collect and process the following personal data: - Driver name - Driver email address - Driver phone number - Login authentication tokens (JWT) - Location data (GPS), including background location, with both precise and approximate accuracy levels - Motion and fitness activity data (movement state such as walking, driving, or stationary) - Photos captured using your device's camera (driver profile photo and location photos in no-show cases) - Uploaded photos from your device's gallery (for driver profile photo) - App crash reports and diagnostic data via Sentry **Profile Photo Storage:** Your profile photo is stored on the company's servers. This photo is used for internal driver identification purposes only and is visible exclusively to company administrators. Your profile photo is not displayed to other app users, passengers, or any third parties. We do not collect personal data beyond what is listed above. ## 3. DEVICE PERMISSIONS The app requests the following device permissions to function properly: **Camera (Android: CAMERA / iOS: NSCameraUsageDescription)** The app requires access to your device's camera to capture photos for operational purposes. This includes: - Taking a profile photo for driver identification (stored on company servers, visible only to administrators) - Capturing location photos as evidence in no-show cases Camera access is only used when you actively choose to take a photo within the app. The app does not access the camera in the background or capture photos without your knowledge. **Photo Library / Media Storage (Android: READ_MEDIA_IMAGES, READ_EXTERNAL_STORAGE / iOS: NSPhotoLibraryUsageDescription)** The app requests access to your device's photo library to allow you to select existing photos for upload. This includes: - Selecting an existing photo from your gallery to use as your driver profile photo - Selecting existing photos from your gallery as evidence in no-show cases Photos selected from your library for profile purposes are uploaded to and stored on the company's servers. Profile photos are visible only to company administrators and are not shared with other app users, passengers, or third parties. You can manage these permissions at any time through your device's settings. **Location – Always On (Android: ACCESS_FINE_LOCATION / ACCESS_BACKGROUND_LOCATION)** The app requires continuous access to your device's location, including when the app is running in the background. This is mandatory for the app to function correctly. Background location access is necessary to: - Provide real-time GPS tracking of driver location - Send location status updates to our dispatch system - Enable accurate pickup coordination with passengers On Android devices, a persistent notification (foreground service) will be displayed while location tracking is active to inform you that the app is accessing your location. **Location – iOS Specific (Precise and Coarse Location)** On iOS devices, the app requests location access with the following options: - **Precise Location (Full Accuracy):** When enabled, the app receives your exact GPS coordinates. This is the recommended setting for optimal app functionality, as it allows accurate driver positioning and precise pickup coordination. - **Coarse Location (Reduced Accuracy):** iOS allows you to grant location access with reduced accuracy, which provides only your approximate location (within several kilometers). While the app will still function with reduced accuracy enabled, this may significantly impact operational effectiveness, including less accurate arrival time estimates and potential difficulties in passenger coordination. The app will request "Always" location permission on iOS to enable background location tracking. You will be prompted to select your preferred accuracy level. We strongly recommend enabling precise location for the best service experience. **Motion & Fitness Activity (iOS: NSMotionUsageDescription / Core Motion)** On iOS devices, the app requests access to motion and fitness activity data from your device's motion sensors. This permission allows the app to detect your current activity state, such as whether you are stationary, walking, or driving. This data is used to: - Optimize location tracking by adjusting GPS polling frequency based on movement state - Improve battery efficiency by reducing location updates when stationary - Enhance the accuracy of driver status reporting to the dispatch system Motion data is processed locally on your device and only aggregated activity states (e.g., "driving", "stationary") are transmitted to our servers. Raw sensor data from the accelerometer or gyroscope is not collected or stored. You can manage these permissions at any time through your device's settings. However, disabling location permissions will prevent the app from functioning as intended. Disabling motion permissions may result in reduced battery optimization and less accurate activity-based features. ## 4. HOW DATA IS COLLECTED Personal data is collected in the following ways: - Directly from the user through the app (e.g., photos taken with the camera or selected from photo library) - Automatically by the app during normal use (e.g., location data, motion activity data, crash reports) - Centrally provisioned driver data before first app access Location data is collected continuously while you are logged into the app, including when the app is in the background. On iOS, the accuracy of location data depends on whether you have granted precise or coarse location access. Motion and fitness data is collected on iOS devices to determine your activity state and optimize app performance. Photos are captured or selected only when you explicitly initiate the camera or photo library function. ## 5. PURPOSE OF DATA PROCESSING We process personal data for the following purposes: - User authentication and access control - Providing core app functionality, including driver status updates and GPS-based tracking services - Real-time location monitoring for dispatch and passenger coordination - Optimizing location tracking and battery usage based on detected motion activity (iOS) - Capturing and uploading photos related to operational use cases (driver identification and no-show evidence) - Internal driver identification through profile photos (visible only to company administrators) - Monitoring app stability and fixing errors through crash analytics ## 6. LEGAL BASIS FOR PROCESSING Personal data is processed based on: - **Performance of a contract** – drivers are under contract with Fox Transfer Brasil prior to using the app; location tracking, motion detection, and photo capture are necessary to fulfill contractual obligations - **Legitimate interest** – maintaining, securing, and improving the functionality of the app, including battery optimization through motion-based location adjustments; internal driver identification through profile photos for administrative purposes - **Consent** – for optional features requiring device permissions ## 7. AUTOMATED DECISION-MAKING We do not use automated decision-making or profiling that produces legal effects or similarly significant effects on you. All decisions regarding your data or any complaints are made manually by our staff. ## 8. DATA SHARING Personal data may be shared with: - Operational partners, specifically HolidayTaxis Group, for service coordination - Sentry (Functional Software, Inc.) for crash reporting and diagnostics **Profile Photo Visibility:** Your driver profile photo is stored internally on our servers and is accessible only to authorized company administrators. Profile photos are not shared with other app users, passengers, operational partners, or any third parties. We do not sell personal data to third parties. ## 9. INTERNATIONAL DATA TRANSFERS Our servers and databases are located within the European Union. Crash analytics data processed by Sentry may be transferred outside the EU. In such cases, appropriate safeguards such as Standard Contractual Clauses and applicable data protection frameworks are used. ## 10. DATA RETENTION Personal data is retained for the duration of the driver's contractual relationship and for a period of 3 (three) years after the contract ends, in accordance with legal and operational requirements. Profile photos are retained for the duration of the driver's contractual relationship and deleted within 3 (three) years after the contract ends. Photos captured for no-show evidence are retained only as long as necessary to resolve the relevant operational case, and no longer than 3 years. Motion activity data is processed in real-time and is not stored beyond the immediate operational session. ## 11. USER RIGHTS Under applicable data protection laws (including GDPR and Brazil's LGPD), you have the right to: - Access your personal data - Request correction of inaccurate data - Request deletion of your data (including your profile photo) - Restrict or object to processing - Request data portability - Withdraw consent for permission-based data collection (camera, photo library, location, motion) We will respond to your request within 30 days. Requests can be made by contacting: info@foxtransfer.com.br **Right to Lodge a Complaint** If you believe your data protection rights have been violated, you have the right to lodge a complaint with a supervisory authority. In Brazil, this is the Autoridade Nacional de Proteção de Dados (ANPD). In the European Union, you may contact the relevant data protection authority in your country of residence. ## 12. DATA SECURITY We use appropriate security measures to protect personal data, including: - Secure hosting infrastructure - Encrypted communication (HTTPS/TLS) - JWT-based authentication - Restricted access controls - Secure transmission of photos and location data - Local processing of motion sensor data before transmission - Access-controlled storage for profile photos (administrator access only) ## 13. CHILDREN This app is intended only for registered drivers. It is not intended for use by children under the age of 18. ## 14. CHANGES TO THIS POLICY This Privacy Policy may be updated periodically. When changes are made, the version number and effective date will be updated. We encourage you to review this policy regularly. ## 15. CONTACT For privacy-related questions or requests, contact: **Email:** info@foxtransfer.com.br **Address:** Rua Carlo Prina, 52 – Brooklin – São Paulo – Brasil – 04601-030 Fox Transfer Brasil Serviço de Receptivo Ltda.