Privacy Statement

First, your privacy is important to us. The kind of thing all these notices might say, but we mean it. You place your trust in us by using Drivegate.com services, and we appreciate that trust. It means that we are committed to protecting and safeguarding your personal data. We act in the best interest of our customers and we are open about how we use your personal data. Thank you for choosing to be part of our community at Drivegate. (“Drivegate“, “Company“, “we“, “us” or “our“). If you have any questions or concerns about this privacy notice or our practices regarding your personal information, please contact us at [email protected].

This privacy notice describes how we might use your information if you:

• Visit our website at drivegate.com • Download and use our mobile application — Drivegate • Engage with us in other related ways ― including any sales, marketing, or events

In this privacy notice, if we refer to:

• “Website,” we are referring to any website of ours that references or links to this policy • “App,” we are referring to any application of ours that references or links to this policy, including any listed above • “Services,” we are referring to our Website, App, and other related services, including any sales, marketing, or events

The purpose of this privacy notice is to explain to you in the clearest way possible what information we collect, how we use it, and what rights you have in relation to it. If there are any terms in this privacy notice that you do not agree with, please discontinue use of our Services immediately. Our offer is subject to Swiss data protection law as well as – if applicable – foreign data protection law, such as in particular that of the European Union (EU) with the General Data Protection Regulation (GDPR). The European Commission recognizes that Swiss data protection law ensures adequate data protection. Please read this privacy notice carefully, as it will help you understand what we do with the information that we collect.

1. INFORMATION COLLECTION

We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and services, when you participate in activities on the Services or otherwise when you contact us. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make and the products and features you use. The personal information we collect may include the following: Personal Information Provided by You. We collect names; date of birth; phone numbers; email addresses; mailing addresses; usernames; passwords (hashed, not visible to us); contact or authentication data; billing addresses; debit/credit card numbers (hashed, not visible to us); your ride history; location data, information about your usage/your learning progress with other users and further similar information. Payment Data. We may collect data necessary to process your payment if you make purchases, such as your payment instrument number (such as a credit card number), and the security code associated with your payment instrument (hashed, not visible to us). All payment data is stored by Stripe. You may find their privacy notice link(s) here: https://stripe.com/en-ch/privacy All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

1.1. Information automatically collected

In short, when you use or navigate our services, we automatically collect certain information to maintain the security and operation of our services, and for internal analytics and reporting purposes. This information may include your Internet Protocol (IP) address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, and information about how and when you use our services.

1.2. We refer to this information as 'Drivegate' data.

The Drivegate data we collect includes:

• Log and Usage Data: This data includes service-related, diagnostic, usage, and performance information that our servers automatically collect when you access or use our services, such as your IP address, device information, browser type and settings, and information about your activity in the services (such as the date/time stamps associated with your usage, pages and files viewed, searches and other actions you take, including which features you use), and device event information (such as system activity, error reports, and hardware settings). • Device Data: We collect device data such as information about your computer, phone, tablet, or other device you use to access our services. Depending on the device used, this data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider, and/or mobile carrier, operating system, and system configuration information. • Location Data: We collect location data such as information about your device's location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access our services. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your location setting on your device. However, note that if you choose to opt-out, you may not be able to use certain aspects of our services.

1.3. Information collected through our Web-App

If you use our Web-App, we collect the above-mentioned Drivegate data, as well as the following information:

• Geolocation Information: We may request access or permission to and track location-based information from your mobile device, either continuously or while you are using our Web-App, to provide certain location-based services. If you wish to change our access or permissions, you may do so in your device's settings. • Mobile Device Access: We may request access or permission to certain features from your mobile device, including your mobile device's calendar, camera, SMS messages, and other features. If you wish to change our access or permissions, you may do so in your device's settings. • Push Notifications: We may request to send you push notifications regarding your account or certain features of our Web-App. If you wish to opt out from receiving these types of communications, you may turn them off in your device's settings.

We collect this information primarily to maintain the security and operation of our Web-App, for troubleshooting, and for our internal analytics and reporting purposes.

2. USE OF YOUR INFORMATION

In short: At Drivegate, we process your personal information for various purposes, such as legitimate business interests, fulfilling our contract with you, complying with legal obligations, and/or with your consent. We use the personal information collected through our services for several business purposes, as described below. We rely on legitimate business interests, your consent, or compliance with legal obligations to process your personal information for these purposes. Furthermore, we indicate the specific processing grounds for each purpose listed below.

We use the information we collect or receive:

• To facilitate the account creation and login process: If you choose to link your account with us to a third-party account (such as your Google or Facebook account), we use the information you allowed us to collect from those third parties to facilitate the account creation and login process for the performance of the contract. • To offer our services: We use your information or user account for the purposes of our platform. This means that certain information is published on our platform and is visible to other users. To provide our service, certain information may also be shared between users. • To post testimonials: We post testimonials on our Services that may contain personal information. Before posting a testimonial, we will obtain your consent to use your name and the content of the testimonial. If you wish to update or delete your testimonial, please contact us at [email protected] and be sure to include your name, testimonial location, and contact information. • Request feedback: We may use your information to request feedback and to contact you about your use of our Services. • To enable user-to-user communications: We may use your information to enable user-to-user communications with each user's consent. • To manage user accounts: We may use your information for the purposes of managing our account and keeping it in working order. • To send administrative information to you: We may use your personal information to send you product, service, and new feature information, and/or information about changes to our terms, conditions, and policies. • To protect our Services: We may use your information as part of our efforts to keep our Services safe and secure, such as fraud monitoring and prevention. • To enforce our terms, conditions, and policies for business purposes, to comply with legal and regulatory requirements, or in connection with our contract. • To respond to legal requests and prevent harm: If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond. • To fulfill and manage your orders: We may use your information to fulfill and manage your orders, payments, returns, and exchanges made through the Services. • To administer prize draws and competitions: We may use your information to administer prize draws and competitions when you elect to participate in our competitions.

To deliver and facilitate the delivery of services to the user: We may use your information to provide you with the requested service.

• To respond to user inquiries and offer support to users: We may use your information to respond to your inquiries and resolve any potential issues you might have with the use of our Services. • To send you marketing and promotional communications: We and/or our third-party marketing partners may use the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. For example, when expressing an interest in obtaining information about us or our Services, subscribing to newsletters, or otherwise contacting us, we will collect personal information from you. You can opt-out of our marketing emails at any time (see the “WHAT ARE YOUR PRIVACY RIGHTS?” below). • Newsletter: By registering for the newsletter and confirming your subscription (double opt-in), we will process the following personal data: your name, first name, email address, and region. This information will be used to authenticate you during registration and to deliver the newsletter to you. Additionally, we will use this data to track whether you have opened the newsletter and clicked on any of its articles.

You have the right to revoke your consent at any time, which can be done by clicking on the “unsubscribe” link in the newsletter. Please note that revoking your consent does not affect any data processing that has already occurred. Drivegate will also use your information to display personalized content and advertising, which may be tailored to your interests and/or location. We may work with third-party providers to achieve this goal, and we will measure the effectiveness of these efforts.

3. SHARING OF INFORMATION

In short: We only share information with your consent, to comply with laws, to provide you with services, to protect your rights, or to fulfill business obligations. We may process or share your data that we hold based on the following legal basis:

• Consent: We may process your data if you have given us specific consent to use your personal information for a specific purpose. • Legitimate Interests: We may process your data when it is reasonably necessary to achieve our legitimate business interests. • Performance of a Contract: Where we have entered a contract with you, we may process and share with other users/third parties your personal information to fulfill the terms of our contract. • Legal Obligations: We may disclose your information where we are legally required to do so to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements). • Vital Interests: We may disclose your information where we believe it is necessary to investigate, prevent, or act regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.

More specifically, we may need to process your data or share your personal information in the following situations:

• Business Transfers: We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company. • Google Maps Platform APIs: We may share your information with certain Google Maps Platform APIs (e.g., Google Maps API, Place API). To find out more about Google’s Privacy Policy, please refer to this link. We use certain Google Maps Platform APIs to retrieve certain information when you make location-specific requests. This includes: Location Data; and other similar information. A full list of what we use information for can be found in this section and in the previous section titled “USE OF YOUR INFORMATION”. We obtain and store on your device (‘cache’) your location. You may revoke your consent anytime by contacting us at the contact details provided at the end of this document. The Google Maps Platform APIs that we use store and access cookies and other information on your devices. • Business Activity: Furthermore, your data can be viewed by authorized persons in connection with business activity. For example, a driving instructor with whom you have or have had a booking will be able to see your contact details as recorded in the app.

4. COOKIES AND OTHER TRACKING TECHNOLOGIES

We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information.

• Cookies – both our own cookies (first-party cookies) and cookies from third parties whose services we use (third-party cookies) – are data in text form that are stored in your browser. Cookies cannot execute programs or transmit malware such as Trojans and viruses. • Cookies can be stored temporarily in your browser as “session cookies” when you visit our website, or for a certain period of time as so-called permanent cookies. “Session cookies” are automatically deleted when you close your browser. Permanent cookies make it possible to recognize your browser the next time you visit our website (to know your language settings or location settings) and thus, for example, to measure the reach of our website. Permanent cookies can also be used for online marketing, for example. • You can disable cookies in your browser settings at any time, in whole or in part, as well as delete them. Without cookies, our website may no longer be fully available. We ask you – if and to the extent necessary – actively for your express consent for the use of cookies. You might encounter performance issues with our services if you disable the cookie functions. • We may collect the following information for each access to our website, provided that this information is transmitted by your browser to our server infrastructure or can be determined by our web server: Date and time including time zone, Internet Protocol (IP) address, access status (HTTP status code), operating system including user interface and version, browser including language and version, individual sub-page of our website accessed including amount of data transferred, website last accessed in the same browser window (referer or referrer). • We store such information, which may also constitute personal data, in server log files. The information is necessary to provide our online offer permanently, user-friendly, and reliably and to ensure data security and thus in particular the protection of personal data – also by third parties or with the help of third parties. • We may use tracking pixels on our website. Tracking pixels are also known as web beacons. Tracking pixels – also from third parties whose services we use – are small, usually invisible images that are automatically retrieved when you visit our website. With pixel counters, the same information can be collected as in server log files. • You can configure your browser settings so that no cookies are stored on your computer. Complete deactivation of cookies may mean that you cannot use all the functions of our website. • By continuing to use our website and/or agreeing to this privacy policy, you consent to cookies being set by us and thus to personal usage data being collected, stored and used, even beyond the end of the browser session. You can revoke this consent at any time by activating the browser setting to refuse third-party cookies.

Personal data is collected for the following purposes using the following services:

5. SAFETY OF YOUR INFORMATION

We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security, and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

6. RIGHTS OVER YOUR OWN DATA

In some regions (like the EEA and UK), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. To make such a request, please use the contact details provided below. We will consider and act upon any request in accordance with applicable data protection laws. If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. Please note however that this will not affect the lawfulness of the processing before its withdrawal, nor will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent. If you are a resident in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: https://ec.europa.eu/info/law/law-topic/data-protection_de. If you are a resident in Switzerland, the contact details for the data protection authorities are available here: https://www.edoeb.admin.ch/edoeb/de/home.html. If you have questions or comments about your privacy rights, you may email us at [email protected].

7. ACCOUNT INFORMATION

If you would at any time like to review or change the information in your account or terminate your account, you can: Log in to your account settings and update your user account. Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms of Use and/or comply with applicable legal requirements. Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of us. To opt-out of interest-based advertising by advertisers on our Services, visit http://www.aboutads.info/choices/. Opting out of email marketing: You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send or by contacting us using the details provided below. You will then be removed from the marketing email list — however, we may still communicate with you, for example to send you service-related emails that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes. To otherwise opt-out, you may contact us using the contact information provided.

Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it in some circumstances. To request to review, update, or delete your personal information, please submit a request by emailing us to [email protected].