EMTRACK Guest Application Privacy Policy

Version 1.0 — effective from October 15, 2026

1. Data Controller

The controller of data processed in connection with the EMTRACK Guest mobile application (the "Application") is EKOSYSTEM sp. z o.o., ul. Gietkowska 10H, 10-170 Olsztyn, Poland, e-mail: kontakt@emtrack.eu (the "Controller").

2. What is the Application

The Application enables a person who has received a temporary access code from an EMTRACK platform user (the "Sender") to view the current position and route history of the designated vehicle for a period specified by the Sender. The Application does not require creating an account or logging in.

3. What Data We Process

Data that the Application DOES NOT collect: first and last name, e-mail address, phone number, Application user's location, contacts, photos, advertising identifiers, usage analytics data.

Data processed for the operation of the Application:

4. System Permissions

The Application does not access or use the user's device location.

5. Purpose and Legal Basis

Data is processed in order to provide the Application's features (Article 6(1)(b) GDPR — performance of a contract/sharing service requested by the Sender) and to ensure service security (Article 6(1)(f) GDPR — legitimate interest of the Controller). Vehicle location data is processed by the Controller on behalf of the Sender (EMTRACK platform customer) as a data processor, based on an agreement with the Sender.

6. Data Retention Period

7. Data Recipients

Data is neither sold nor shared with third parties for marketing purposes. Maps in the Application are provided by Google Maps Platform (Google Ireland Ltd.) — when displaying the map, the device communicates with Google servers in accordance with the Google Privacy Policy. EMTRACK servers are located within the European Union.

8. User Rights

You have the right to access your data, rectify it, erase it, restrict its processing, object to processing, and lodge a complaint with the President of the Personal Data Protection Office (PUODO) or your local supervisory authority. For matters concerning vehicle data, the appropriate point of contact is the Sender (fleet owner). Contact details for the Controller: kontakt@emtrack.eu.

9. Changes to the Privacy Policy

We will inform users of any changes to this Privacy Policy by publishing a new version at this address and in the Application description on Google Play.