PRIVACY POLICY

FOR THE DRB APP

INTRODUCTION

The DRB App is a product owned by Interactive Smart Communications Company (from here on referred to as ISCC), A company headquartered in Riyadh, Saudi Arabia, Near Mathar Civil Defense, Umm Al Hamam Al Sharqi.

We take your privacy seriously and are fully committed to handling the information we collect from you in a secure and responsible manner. We are dedicated to protecting and respecting your privacy.

This policy sets out the basis upon which any personal information we collect from you, or that you provide to us, will be processed by us when you are using our webportal including our apps (the "Sites") for the purposes of the Saudi Arabia's Personal Data Protection Law ("PDPL") and the Data Protection Act 2021. The terms defined in the PDPL "Data Processor" The individual to whom the personal data relates, his representative or his legal guardian, and "Data Controller" Any public entity, and any natural or legal person; specify the purpose and method of processing personal data; Whether the data is processed by it or by the processor.

By registering with us or by allowing a User to register with us on your behalf, you agree that we may contact you in relation to the management of your account with us. You can update your preferences by logging in to your account on the mobile application and changing your settings, or by emailing us or writing to us. Please see the 'Contact us' section of this Privacy policy.

LAWFULNESS OF PROCESSING

The personal data collection and processing by ISCC is performed in a legitimate interest basis.

COLLECTING AND USING YOUR PERSONAL INFORMATION

What personal data are we collecting?

We will collect and process the following personal information ("Personal Data") about you:

- some mandatory and optional Personal information such as, name, birthdate, gender, contact info and address.

- Information about your vehicle, including vehicle type, fuel type and brand name.

- Mobile device data (including device identifier (e.g. UDID), subscriber identifier, operating system type, and version, and Internet Protocol (IP) address)

- Technical information (including IP address, time zone setting, location data, operating system, and platform)

- Information about "DRB App" usage (including installation, removal, screen interactions, interface interactions, and crashes)

- Your and your vehicle's exact location, speed, and direction of travel

- Usage of smartphone whilst driving, in particular, the fact of being into a call, locking and unlocking the screen

- Mobility patterns before and after a driving session, including the mobility mode (i.e., walking, cycling, stationary, running), the time, the confidence interval, and the location of the place the mobility mode was detected.

Optionally, the user would be able to provide ISCC with Personal information (a number of questions related to driving and insurance habits). This Personal information is non-mandatory, and the user would be able to submit it through a secure web form.

We do not collect any sensitive data concerning Users such as racial or ethnic origins, political, philosophical or religious opinions as well as any data relating to trade union membership, or health.

WHAT WILL WE DO WITH THIS DATA?

Your data will be analyzed to either:

A) pilot and showcase the "DRB App" and technology suite as part of commercial conversations ("demo of the platform") with you or your company.

B) In the context of usage-based-insurance programs offered through the "DRB App".

C) and/or in the context of fleet management and driver behavior improvement programs offered through the app.

Some of these referenced programs might have entry restrictions. ISCC reserves the right to define and communicate the entry restrictions to each respective program.

We also may do work with academic partners in the field of data analytics and in the context of research and development projects that involves sharing some of your non-individually identifiable Personal Data (e.g. interactions, session length, device type) and we may store communications data (e.g. details of queries or complaints received by phone, email or text)

Notwithstanding any other provision of this policy, we will never share any information on your location with any party other than the User, and to the User only upon request in the event of an incident and upon such request only trip logs relating to the trip in which the incident occurred.

STORAGE AND DELETION OF YOUR PERSONAL DATA

All Personal Data you provide to us will be stored on our secure servers inside KSA, or those of our sub-processors. Our platform and APIs are regularly penetration tested to the highest standards to ensure the security of our system. Where you are based in the SAUDI ARABIA, we have put in place appropriate safeguards with your employer and our sub-processors to ensure that you are able to enforce all the rights afforded to you under the Personal Data Protection Law of the Saudi Arabia's PDPL.

We will use strict procedures and security features to try to prevent unauthorized access to your Personal Data. Any data breaches will be notified to the User as a data controller.

We will keep information no longer than we need to for the purpose for which we collected it. We keep personal information for a period of 12 months from the date the user account is deleted. After the end of this retention period, Personal Data will either be deleted or anonymized.

Disabling the permissions of "Location Services" and "Physical Activity" allows you to pause geo-tracking and all data collection at any point in time. When these permissions are disabled, Personal Data relating to your location or driving behavior will not be collected or stored.

ISCC holds a record of processing activities that is at the disposal of the User as a data controller.

YOUR RIGHTS

ISCC will assist the User as the data controller to allow for the exercise of your rights.

You can refuse to accept the terms of this privacy policy if you do not provide your consent to such terms during the sign-up process to the "DRB App", in which case we will not collect any of your Personal Data (other than the very limited Personal Data that we have collected in the sign-up process to that point, which you may request to be deleted as below).

Withdraw of consent: you can withdraw your right to consent to this Privacy Policy at any time by contacting us at info@iscc.com, following the Personal Data Protection Law of the Saudi Arabia's PDPL. As soon as reasonably practicable after receiving such notification, we will stop collecting any of your Personal Data. In particular, you can withdraw your consent for data collection by denying mobile phone permissions from your mobile phone app settings.

Data deletion: You can request the deletion of your Personal Data at any time.

Data rectification: if you believe that any of your personal data processed by ISCC is inaccurate, you can exercise your right to rectification of such personal data by contacting ISCC at info@iscc.com. ISCC will respond to any such request as soon as possible, and in any event within two working days.

Data portability: You can request ISCC a copy of your raw collected data for the purpose of portability.

Object to processing: You have the right to object processing and using your personal data at any time, following the conditions of the Personal Data Protection Law of the Saudi Arabia's PDPL.

Lodge a complaint: You have the right to lodge a complaint following the conditions of the Personal Data Protection Law of the Saudi Arabia's PDPL.

Restriction of processing: You have the right to restrict us from processing your personal data where one of the following applies: (i) you contest the accuracy of your personal data, (ii) the data has been unlawfully processed, (iii) you need us to keep your data it in order to establish, exercise or defend a legal claim; or (iv) you have objected to us processing your data following the conditions of the Personal Data Protection Law of the Saudi Arabia's PDPL

CHANGES TO OUR PRIVACY POLICY

Any changes we may make to our privacy policy in the future will be posted in the "DRB App" and, where appropriate, notified to you by email and made available online on our website.

None of our cookies store personal information such as your name, address or financial details, or any other sensitive information about you without your express permission to do so.

CONTACT INFORMATION

You can exercise your right to access the Personal Data that we hold about you, and you can withdraw your right to consent to this Privacy Policy at any time by contacting us at:

ISCC, Near Mathar Civil Defense, Umm Al Hamam Al Sharqi, Riyadh 12345, Saudi Arabia

Or Email us on:

info@iscc.com