This Privacy Policy is intended for individuals who are visiting a website or using a mobile application (”app”) from one of the companies of the Amodo group. As a result, this company is processing information about you which constitutes “personal data”.

Amodo is responsible for the processing of your personal data as it decides why and how it is processed, thereby acting as the “controller”. In this Privacy Policy, “Amodo”, “we” or “us” refers to Amodo d.o.o., Ulica Frana Folnegovića 1/C, HR-10000 Zagreb,
Croatia and its affiliates. Your privacy is important to us, and so is being transparent about how we collect, use, and share information about you. In this Privacy Policy you can find following information:

• What information do we ask you to provide directly to us and why
• What information does Amodo d.o.o. collect and access, when it is used and why
• What information might be collected from other sources
• To which third parties may we transfer your data
• How we store and secure information we collect
• How to access and control your information
• Other important privacy information

Scope and Application

Amodo collects and holds information about you when you sign up for and use the Amodo mobile applications and when, through your use of Amodo mobile applications or otherwise, you purchase insurance or have any communications with Amodo for these purposes and when you use our websites or other services/products that you have applied for. This Privacy Policy sets out what and how information is collected, why it is collected, to whom it may be transferred and how you may gain access to/request correction of such information or change your choice with regards to receiving promotional material. It is entirely voluntary for you to provide such information, but there is certain information you must provide:

a) to access Amodo mobile applications in the first place,
b) to use all functionalities of Amodo mobile applications and
c) to access our other products/services that we offer.

By signing up to use Amodo mobile applications or other products/services you agree to the information you submit or which is collected through Amodo mobile applications or other products/services being collected, processed, used and transferred in the manner identified in this Privacy Policy. If you do not agree with this policy, do not access or use our Amodo mobile applications or interact with any other aspect of our business or products/services that involves processing of personal data.

Where we provide the mobile applications or other products/services under contract with an organization (for example the client such as insurance company, rent-a-car company etc.) that organization controls the information processed by the mobile applications or other products/services. In such case that organization is acting as a controller.

What information do we ask you to provide directly to us and why?

You will note that we collect your email address when you first register for Amodo mobile applications or other certain products/services and ask you to complete certain information in the Profile section of the application or other products/services. The information we ask you to provide and why is as follows and may vary from different products/services:

Your e-mail address – When you first download Amodo mobile applications we ask you to provide your e-mail address, which we use to generate a password for you. Without you providing this information, therefore, you will not be able to access Amodo mobile applications. We also use this to communicate with you on queries you have on, or to provide you with information in relation to Amodo mobile applications. Further but only if you have exercised your right to “opt in” of receiving promotional material, we may use this to send you special promotions of our insurance products.
We also use your e-mail address when you’re using our other products/services if that is necessary in order to use that products/services and if we have obtained prior consent from you.

Your name – We collect both your first name and your surname (family name). Your first name will be your display name displayed on Amodo mobile applications with your score so other users of Amodo mobile applications will be able to see this. You need to provide this otherwise you cannot use Amodo mobile applications. If you choose to enter into any competition, we also ask that you provide your surname/family name as a condition of doing this, for identification purposes (along with your first name).

We also use your name and address when you’re using our other products/services if that is necessary in order to use that products/services and if we have obtained prior consent from you.

Address/City/Phone number – You may use Amodo mobile applications without filling in this information. However, we do give you the option to enter this information. The purpose of asking for this information is to provide us with alternative means of communicating with you about Amodo mobile applications if you have any queries (for example, if we cannot get hold of you by your e-mail address).
We also use your phone number when you’re using our other products/services if that is necessary in order to use that products/services and if we have obtained prior consent from you.

Birthday – You may use Amodo mobile applications without filling in this information. However, we do give you the option to enter this information. The purpose of asking for this information is that it provides us with a check on your eligibility to use Amodo mobile applications. It is also another check on your identification. Further (unless you have exercised your right to “opt out” of receiving promotional material), we may use this to send you special promotions of our insurance products related to your birthday.

Car make/car model/car year/vehicle registration number – We collect this information to ensure Amodo mobile applications works accurately for your purposes (the make, model and year of the car are important for that), but also for eligibility and identification purposes. You are only eligible to use Amodo mobile applications if you are a qualified driver with a registered vehicle. As such, the provision of this information is a necessary condition of you accessing the functionality of Amodo mobile applications.

Expiry date of your current car insurance – This information is not mandatory for you to provide in order to use Amodo mobile applications. We may use this information for reminding you of the discount you could obtain for your insurance, based on your Amodo mobile applications score, at the time your insurance comes up for renewal, if you fill this in.

Other information – in such case we always transparently ask you to provide your information at your disposal and we always define the purposes of using that information in advance (e.g. name of the company you work for, your job title or position etc.)

What information does Amodo mobile applications collect and access when it is used and why?

When you sign up for Amodo mobile applications, you will note that we indicate Amodo mobile applications requires access to certain information. This information, the reasons access to it is required and the time at which it is accessed are set out below:

Location Information – Amodo mobile applications functions by collecting precise location data about your trip when you drive. This is necessary to enable Amodo mobile applications to detect your acceleration, cornering, speed and other measurements which make for safe driving. It is therefore necessary for permission to be given through the permission system of your mobile operating system for Amodo mobile applications to be used for its main purpose of assessing your record as a safe driver.

Motion Detection – To record the safety measurements of your driving (accelerating, cornering, speed, braking) Amodo mobile applications needs to access the activity recognition functionality of your mobile phone’s operating system. It is therefore necessary for permission to be given through the permission system of your mobile operating system for Amodo mobile applications to be used for its main purpose of assessing your record as a safe driver.

Network/WiFi states – Amodo mobile applications collects the location information in real time whilst you are online. If, however, that connection is interrupted the information is stored locally until a connection is available. It is therefore necessary for permission to be given through the permission system of your mobile operating system for Amodo mobile applications to be used for its main purpose of assessing your record as a safe driver

Contacts Information – Amodo mobile applications provides you with the functionality to invite friends in your contacts list to register for Amodo mobile applications. If you wish to do this, however, it is necessary for you to permit access to the address book on your device through the permission system used by your mobile phone platform. We will only use such information if you use the “Invite friends” function.

Call and SMS Data – As a safety feature, Amodo mobile applications has the functionality to turn on automatic call and SMS replies for incoming calls and SMS’s received whilst Amodo mobile applications is being use to record a driving trip. This enables you to drive without interruption and improve your safety. It is optional for you to use this function. If, however, you choose to use it, it is necessary for you to permit access to the SMS and call functions through the permission system used by your mobile phone platform. We will only utilize these functions for the stated purposes.

Important information about platform permissions

Most mobile platforms have defined certain types of device data that apps cannot access without your permission and platforms provide different permission systems for gaining your consent. The iOS platform alerts you the first time Amodo mobile applications wants access to a particular function (usually the first time you use that function) and asks you to give permission for that function to be used at that point. Android devices will notify you of all the permissions Amodo mobile applications may need for all functions when you first register for the app and your use of the app constitutes your consent. The above explanations, we hope, gives you full details of the functionalities which Amodo mobile applications needs access to, why and when it will use them.

What information might be collected from other sources

A feature of Amodo mobile applications enables you to share your score and other information on your social media sites. Your use of such features enables the sharing of information with your friends or the public, depending on the settings you set with your social media service. Please check the privacy policies of your social media sites for further information.

Our Amodo mobile applications make use of social network plugins (“Plugins”). When you use a Amodo mobile applications that contains Plugins, information may be directly transferred from your device to the operator of the social network. We have no influence on the data gathered by the Plugin. If you are logged into the social network, your use of our Service can be referenced to your social network account. If you interact with the Plugins, for example by clicking “Like”, “Follow” or “Share”, or enter a comment, the information may automatically show in your social network profile. Even if you are not logged into your social network account, it may be possible that the Plugins transmit your IP address to the social network operators. Please consider this when using our Services.

For information about the social network operators of the Plugins used in our Amodo mobile applications please see below:

Facebook

• Data controller: Facebook Ireland Limited, Hanover Reach, 5-7 Hanover Quay, 2 Dublin, Ireland (“Facebook”). For further information you may visit Facebook’s privacy policy website at https://www.facebook.com/about/privacy/.

Google+

• Data controller: Google Inc., Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”). For further information you may visit Google’s privacy policy website at http://www.google.co.uk/intl/en/policies/terms/regional.html.

Legal bases for processing (for EEA users)

If you are an individual in the European Economic Area (EEA), we collect and process information about you only where we have legal bases for doing so under applicable EU laws. The legal bases depend on the services you use and how you use them. This means we collect and use your information only where:

• We need it to provide you the mobile applications or other products/services, including to operate the mobile applications or other products/services, provide customer support and personalized features and to protect the safety and security of the mobile applications or other products/services;
• It satisfies a legitimate interest (which is not overridden by your data protection interests), such as for research and development, to market and promote the mobile applications or other products/services and to protect our legal rights and interests;
• You give us consent to do so for a specific purpose; or
• We need to process your data to comply with a legal obligation.

If you have consented to our use of information about you for a specific purpose, you have the right to change your mind at any time, but this will not affect any processing that has already taken place. Where we are using your information because we or a third party (e.g. your employer) have a legitimate interest to do so, you have the right to object to that use though, in some cases, this may mean no longer using the mobile applications.

To which third parties may we transfer your data?

We share information with third parties that help us operate, provide, improve, integrate, customize, support and market our Amodo mobile applications or other products/services.

Information collected through Amodo mobile applications or other products/services is collected on cloud servers run by a third party cloud hosting provider. The information is also downloaded to Amodo which utilizes shared service hubs run by Amodo affiliate or third party cloud hosting companies for data storage and management. On-going application support for Amodo mobile applications or other products/services is provided by a third party software service provider with whom Amodo contracts, who in providing such support requires access to the data collected through Amodo mobile applications or other products/services.

For the above third parties to have the data access required, data collected through Amodo mobile applications or other products/services is transferred to places outside of the country where they have been gathered (where the cloud data centers and Amodo data centers are based and where the service providers are based). Where such a transfer is performed, it will be done in compliance with the requirements of the Personal Data (Privacy) legislation. The countries/jurisdictions to which personal data is transferred by Amodo include, without limitation, the European Union.

In case of transferring the personal information outside of European union to third parties in countries that may not have equivalent privacy and data protection laws to the country in which Amodo mobile applications or other products/services reside when information of data subjects in the European Economic Area or Switzerland is shared, Amodo mobile applications or other products/services make use of the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks, European Commission-approved standard contractual data protection clauses or other appropriate legal mechanisms to safeguard the transfer.

How we store and secure information we collect

We use data hosting service providers in the European Union to host the information we collect, and we use technical measures to secure your data.

While we implement safeguards designed to protect your information, no security system is impenetrable and due to the inherent nature of the Internet, we cannot guarantee that data, during transmission through the Internet or while stored on our systems or otherwise in our care, is absolutely safe from intrusion by others.

How long we keep information

How long we keep information we collect about you depends on the type of information. After such time, we will either delete or anonymize your information or, if this is not possible (for example, because the information has been stored in backup archives), then we will securely store your information and isolate it from any further use until deletion is possible.

How to access and control your information

Promotional Communications

The discount feature of Amodo mobile applications enables you to see the type of premium discount you may be able to obtain based on your driving record.

In addition to this, however, subject to prior consent from your side we wish to use your contact information (e-mail address, phone number, address) to contact you from time to time about insurance products which may be of interest. In the context of Amodo mobile applications or other products/services this may include contacting you on or around your birthday or on the date your current car insurance expires with special offers (which is why we ask to collect this date from your). You may opt out of receiving such promotional messages from us at any time by following the instructions on those messages, or alternatively, by contacting us at dpo@amodo.eu.

Upon receipt of any opt-out request from you, Amodo will, at no cost to you, act on your request and ensure that your personal data will not be used as indicated in your request.

No Information Collected from Children

We will never ask for or knowingly collect information from children. We are strongly committed to preserving online privacy for all of our web site visitors, including children. We do not knowingly collect information about children or sell products to children. Consistent with the Children’s Online Privacy Protection Act, we will not knowingly collect any information from children under the age of 16.

Your right of access and correction

In respect of any personal data collected from you and held by us through Amodo mobile applications or other products/services, you have the following rights:

1. to check whether Amodo holds data relating to you and to access such data;
2. to require Amodo to correct any data relating to you which is inaccurate;
3. to ascertain Amodo ’s policies and practices in relation to personal data and to be informed of the kind of personal data held by Amodo ;
4. to object to our use of your information (including for marketing purposes);
5. to request the deletion or restriction of your information, or to request your information in a structured, electronic format.

To exercise any right of access and correction of personal data above you may write to the Data Protection Officerof Amodo at dpo@amodo.eu. The Data Protection Officer of Amodo will, upon satisfying itself of the authenticity and validity of the access request, make every endeavour to comply with and respond to the request within the period set by the Personal Data (Privacy) legislation. In accordance with the terms, Amodo has the right to charge a reasonable fee for the processing of any data access request.

Your request and choices may be limited in certain cases: for example, if fulfilling your request would reveal information about another person, or if you ask to delete information which we or your administrator are permitted by law or have compelling legitimate interests to keep. Where you have asked us to share data with third parties, for example, by installing third-party apps, you will need to contact those third-party service providers directly to have your information deleted or otherwise restricted. If you have unresolved concerns, you may have the right to complain to a data protection authority in the country where you live, where you work or where you feel your rights were infringed.

Changes to our Privacy Policy

We may change this Privacy Policy from time to time. We will post any Privacy Policy changes on the Internet or mobile applications page and, if the changes are significant, we will provide a more prominent notice by adding a notice on the mobile applications homepages, login screens, or by sending you an email notification. We encourage you to review our Privacy Policy whenever you use the mobile applications to stay informed about our information practices and the ways you can help protect your privacy.

If you disagree with any changes to this Privacy Policy, you will need to stop using the Services and deactivate your account(s), as outlined above.

This Privacy Policy is updated and becomes effective on 15th of January 2019.