Privacy Policy Last Updated: December 6, 2023

Paxmobility website or the mobile application, all of which are part of Paxmobility’s Platform ("the Platform") is operated by VILMATE CORPORATION LTD, company number 10236123, 77 Hurn Way, Christchurch, England, BH23 2NY, hereinafter referred to as “Company”, "us," "we," and "our." This privacy policy outlines the information processing procedures related to the Platform. Any terms not explicitly defined in this document carry the definitions provided in our Terms of Service.

  1. Data Controller and Processor

    Depending on the specific data and the nature of its processing, the Company may act as either a Data Controller or a Data Processor. This role determination is made in compliance with applicable data protection regulations and is as follows:

    • Data Controller: The Company may act as a Data Controller when determining the purposes and means of processing Technical and Usage Data independently. In such cases, the Company takes full responsibility for data processing activities.
    • Data Processor: The Company may also function as a Data Processor when processing Identity and Contact Data on behalf of the driving school. We collect these personal data exclusively for the driving schools, following their instructions. This means the driving school controls personal data you provide on the Platform. In this role, the Company is the Data Processor, and the driving school is the Data Controller. As the Data Controller, the driving school must comply with the General Data Protection Regulation or other applicable regulations.

    If you have questions about our role as a Data Processor or Data Controller, you can submit your questions or request using our contact form.

  2. Data we collect
    • Identity Data includes your name, last name, date of birth, place of birth;
    • Contact Data includes your phone number, email address, address;
    • Technical Data includes information about how you access the Platform, such as: IP address, login details, the type and version of your web browser, your time zone and location, types and versions of browser add-ons, operating system and device platform, other technical details about the devices you use to visit the Platform;
    • Usage Data refers to details about how you interact with the Platform.
  3. How we collect your personal data
    • Direct Interactions

      We obtain your Identity, Contact Data through direct interactions when you сreate an account on the Platform. Through the "Personal Data Management" feature, you can view and edit the Identity and Contact Data associated with your account. When you submit inquiries via our contact form, the details provided in the request form will be processed for the purpose of addressing and storing your request.

    • Automated Technologies or Interactions

      We automatically collect Technical Data in so-called server log files that are automatically transmitted to us by your browser.

    • Driving Schools

      The Driving School may have already collected some of your information and entered it into the Platform. If you want this information deleted, corrected, or wish to exercise any of your data subject rights, please contact your Driving School.

  4. How we use your personal data

    The lawful bases we rely on for processing personal data are:

    • When it is necessary to fulfill a contract we have with you, such as our Terms of Service;
    • When it is in our legitimate interest to process the data;
    • Where we need to comply with a legal or regulatory obligation;
    • When we have obtained your consent.

    We collect your data so that we can:

    • Enable students to create accounts;
    • Efficiently administer and operate the Platform;
    • Notify you of important information relating to your account.
  5. Your rights under GDPR
    • The right to access

      You have the right to request for copies of your personal data.

    • The right to rectification

      You have the right to request that we correct or complete any information you believe is inaccurate or incomplete.

    • The right to erasure

      You have the right to request that we erase your personal data, under certain conditions.

    • The right to restrict processing

      You have the right to request that we restrict the processing of your personal data, under certain conditions.

    • The right to object to processing

      You have the right to object to our processing of your personal data, under certain conditions.

    • The right to data portability

      You have the right to request that we transfer the data that we have collected to another organization, or directly to you, under certain conditions.

    • The right to withdraw consent

      You have the right to withdraw your consent, where the processing of your data is based on your consent. If you withdraw your consent, we may not be able to provide you with access to all or parts of our websites and service.

    • The right to complain

      The right to complain with the supervisory authority responsible for data protection matters. The competence for complaints is split among different data protection supervisory authorities in Germany. Competent authorities can be identified according to the list provided under www.bfdi.bund.de/anschriften.

    You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

    We have a one month time frame to respond to your request. If you would like to exercise any of these rights, please contact us using our contact form.

  6. Data sharing and transfer

    The data collected from students is shared with the respective driving school where the student is enrolled.

    The Platform leverages services provided by Amazon Web Services (AWS) within the jurisdiction of Germany (hoster). The personal data collected on the Platform is stored on the servers managed by the hoster. Our hoster processes your data solely to the extent required to fulfill its contractual obligations and adheres to our instructions regarding this data. To ensure the data is processed in compliance with data protection regulations, we have established a contractual agreement for order processing with our hoster.

  7. Data security

    We have implemented security measures to uphold the highest standards of data protection and user privacy. These measures include:

    • Token-Based Authentication: Implementation of token-based authentication for enhanced security.
    • User Roles and Data Isolation: Establishment of distinct user roles with specific access levels, ensuring the isolation of users' data from each other.
    • Pseudonymisation and Encryption: Employment of pseudonymisation and encryption techniques for passwords, including one-time SMS passwords with short life spans.
    • Ongoing System Integrity: Capability to maintain the ongoing confidentiality, integrity, availability, and resilience of our processing systems and services.
    • Disaster Recovery: Ability to promptly restore the availability and access to personal data in the event of a physical or technical incident.
    • Regular Testing and Evaluation: Implementation of a systematic process for regularly testing, assessing, and evaluating the effectiveness of technical and organizational measures, ensuring the security of our data processing.
  8. Data retention

    The retention period for the data collected and processed by the Platform is set at five (5) years. As a Data Processor, we are committed to retaining personal data in accordance with the policies and instructions of the Data Controller, which is typically your driving school. We do not independently determine the data retention periods for personal data.

  9. Children

    Individuals under the age of 16 are not permitted to use the Platform without supervision. If you are under the age of 16, you may only use the Platform under the guidance and supervision of your parents or legal guardians.

  10. Changes to the privacy policy

    We may update this Privacy Policy. If you have an active Paxmobility account, we will notify you of updates to the Privacy Policy through in-app notifications. We recommend checking this Privacy Policy periodically to stay informed and ensure you are aware of any updates.