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:
- access code (token) entered manually or scanned from a QR code — stored locally on the device and transmitted to EMTRACK servers to verify and retrieve vehicle data;
- vehicle data shared by the Sender: vehicle name/registration number, GPS position, status (moving/stationary/ignition), route history — retrieved from EMTRACK servers and displayed in the Application; this is the Sender's (fleet owner's) data, not the Application user's data;
- random Application instance identifier generated locally upon first launch — used solely for the operation of the Application on the device and not transmitted to the Controller;
- technical connection data (IP address, request timestamps) — recorded in EMTRACK server logs to ensure security and prevent abuse (e.g., rate limiting).
4. System Permissions
- Camera (CAMERA) — used solely to scan the QR code containing the access code. Camera images are processed locally on the device and are neither stored nor transmitted.
- Internet — communication with EMTRACK servers (encrypted via HTTPS).
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
- The access code and vehicle data are stored on the device until the access expires, is revoked by the Sender, or the vehicle is removed from the Application by the user; uninstalling the Application deletes all local data.
- Technical server logs are retained for a period no longer than 90 days.
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.