Personal Data Privacy Policy

Last Modification date: 12th of July 2024

Below You will find Our detailed Personal Data Privacy Policy.

Please read the Personal Data Privacy Policy carefully before using the Services of the Application “O7Drive” (the “Application”).

Please also note that by accessing, browsing and using the Application, You certify that You have read, understood, agreed to and ultimately accepted the Personal Data Privacy Policy.

If, after having read the Personal Data Privacy Policy, You find that for any reason You do not agree with and do not accept any of its content and provisions, You are kindly requested not to install the Application or to immediately delete it from Your smartphone, tablet or any other electronic device You may have installed it and not to use it in any manner.

The Application is developed and operated by "OSeven Telematics Limited", a private limited liability company organized and existing under the laws of England and Wales and having its corporate seat in London and its official address at 35, Ballards Lane, London, United Kingdom N3 1XW (hereinafter referred to as "OSeven"). OSeven operates as Data Controller for all personal data processed by the Application, as described below.

OSeven shares Your data with its subsidiary company “OSeven Single Member Private Company”, existing under the laws of Greece and having its corporate seat in Greece and its official address at 27B, Chaimanta street, Chalandri, Attica (hereinafter referred to as “OSeven GR”).

OSeven reserves the right to update / modify / amend the Personal Data Privacy Policy, whenever it deems that it is necessary. To this end, the update / modification / amendment will be available to You via the Application and the Last Modification Date will be indicated under the title of the Personal Data Privacy Policy, so that You will be notified thereof. If OSeven proceeds to making significant updates / modifications/ amendments to the Personal Data Privacy Policy, OSeven shall promptly notify You via email and/or notifications/messages through the Application. The use of the Application after the Last Modification Date indicates Your acceptance of these updates / modifications / amendments. If You do not agree with any update / modification / amendment, You must delete the Application and not use it anymore.

If, despite reading the following Personal Data Privacy Policy, You still have any questions regarding the Personal Data Privacy Policy or in case You need further clarifications or information, You may contact the Data Protection Officer of OSeven, Mr. Konstantinos Kakavoulis by email at dpo@oseven.io.

All definitions may be found in the Terms of Use of the Application (the “Terms”).

1. Collection and processing of Your personal data

  1. We have created this Personal Data Privacy Policy for the collection and management of personal data to inform You that Your personal data will be treated properly, with the required level of security, complying with the General Data Protection Regulation of the European Union (EU GDPR) and any other applicable legislation. The personal data We process upon Your registration to the Application (i.e., Your email) or upon the acceptance of the invitation that You have received (e.g., via Your email) to use the Application, is the minimum information required for the provision of professional services on Our part.
    Please note that the following information that We collect is provided to OSeven only with Your explicit consent, given before the installation and use of the Application and after You obtain knowledge of this Personal Data Privacy Policy.
    Please note that Your email will be used solely to identify You as a User of the Application or to contact you for any issues related with the Application. Please note that You are solely responsible for keeping any sign in emails to Your account confidential and that You are fully responsible for any activities in Your account.
  2. The legal basis for the processing of Your personal data (email, Primary Data, Driving Behaviour and Vehicle Use Data, Reward Data) is the explicit consent that You provide to the Application based on the Terms of Use and Personal Data Privacy Policy; whereas in case that OSeven is requested to disclose Your personal data to a public authority, the legal basis for this process is the compliance of OSeven with its legal obligations. If OSeven processes Your data to receive feedback by You for the use of the Application, it shall do so based on Your explicit consent.
  3. The type of data that We may collect with Your consent, which is given herewith, is listed below.

2. Collection of Your Primary Data

“Primary Data”: Primary Data refers to the data recorded by the Application from the smartphone sensors or the operating system of the smartphone or data that You may provide to the Application. Primary Data is provided to OSeven by the manufacturers and developers of the smartphone operating system (Apple: iOS, Google: Android) or by You.

The Application may collect and assess Primary Data related with driving activity (including Location data) to enable the automatic Trip recording even when the Application is closed or not in use. Specifically, the Application is activated by data received from the Android and iOS operating systems to verify if the User is in a driving status. This process is called “Driving Detection”. If the Application verifies that the User is in driving status, then the recording of Primary Data begins. Otherwise, data collection is interrupted, until the next time that the Application is activated. In case that the User is not in a driving status the data collected during “Driving Detection” is not sent to the O7PLATFORM and is immediately deleted from the smartphone device. Regarding the Primary Data that is related with driving behaviour, only the Primary Data that is recorded during a Trip is sent to the O7PLATFORM.

The Primary Data that is sent to the O7PLATFORM, is stored by OSeven in servers within the European Union utilizing recognized and acknowledged technology providers (Amazon Web Services, Microsoft).

The Primary Data is the following:

All the above-mentioned data helps us extract the Driving Behaviour and Vehicle Use Data and the Reward Data as mentioned below under section 4 and proceed with the necessary profiling for each User.

The Application also records data, information and events related to the operation of the Application in Log Files to ensure that any feedback You provide is supplemented with the necessary information. These Log Files remain in Your smartphone device for a rolling time window of five (5) days and, after that, they are deleted. In case that You provide feedback, You will be asked to provide Your explicit consent in order for the stored Log Files in Your smartphone device at the time of the request to be sent to the O7PLATFORM. Your Log Files will be stored in the O7PLATFORM for a period of thirty (30) days. The Log Files may include any of the aforesaid Primary Data that may have been recorded at any time.

3. The purposes of collecting, storing and processing of Your data

The purposes of collecting and processing of the email address of the Users and the “Primary Data” are the following:

Specifically, regarding data which pertain to the longitude and latitude of the Location data, this is stored and kept in the O7PLATFORM for the following purposes:

OSeven shall receive and retain the data of the Trips that the Users were not the driver of the vehicle for the following purposes: (i) transparency to the Users, (ii) to provide to the Users the option to access and modify their data, (iii) optimization of the reliability of the results provided to the Users and (iv) the optimization of the data models and algorithms (indicatively the driving behaviour models and the machine learning algorithms) in the O7PLATFORM, also improving the provided Services to the Users.

Following the assessment of the above, the Driving Behaviour and Vehicle Use Data and Reward Data which correspond to Your actual driving behaviour are calculated by OSeven, as described below.

4. Calculation of Driving Behaviour and Vehicle Use Data and Reward Data

The Driving Behaviour and Vehicle Use Data is the data of the User derived from the Primary Data via processing in the O7PLATFORM and/or the Application using advanced mathematical algorithms and/or machine learning algorithms, as well as advanced driving behaviour models. We create and keep a specific profile for each User in Our database so that the relevant Driving Behaviour and Vehicle Use Data correspond to a “Score” (see below for the weighing factors that affect the “Score”). Users may request more information, via the procedure set out below, regarding their profile. However, it is noted that it is not in any case possible to access or receive information about the code/algorithm/model of OSeven, since these constitute OSeven’s own intellectual property protected by the relevant legislation.

Driving Behaviour and Vehicle Use Data are indicatively the following:

“Score”: The driving behaviour model of OSeven provides a score from 0 (lowest) to 100 (highest) per Trip, considering the following parameters, with decreasing level of significance:

“Eco Score”: If you choose to activate the fuel consumption feature, the driving behaviour model of OSeven provides an Eco Score from 0 (lowest) to 100 (highest) per Trip., considering the following parameters:

The overall Score and the Eco Score of the User is calculated as the weighted average of the Trips’ Scores and Eco Scores of the last twelve (12) months, where the User was the driver (according to the estimation of the machine learning algorithms of OSeven or the characterization of the User; the characterization of the User prevails), with distance as the weighting factor.

“Reward Data”: OSeven has developed gamification and rewarding features for the training and the motivation of the Users in order to improve their driving behaviour. The Reward Data includes mainly the following:

5. Time periods for the collection and processing of Your Data

  1. Your Primary Data is stored in the O7PLATFORM within the European Union.
  2. You have the option to deactivate Your account by contacting OSeven at the email support@oseven.io at any time.
    Two (2) years after the deactivation or termination of Your account Your personal data will be anonymized in a way that it is not reversible. In this way Your data and consequently location data cannot be related in any way with You anymore.
  3. Data we collect through Log Files are stored in the O7PLATFORM for thirty (30) days and are subsequently deleted.
  4. If the Application determines that the User is not in a driving status the data collected during “Driving Detection” is not sent to the O7PLATFORM and is immediately deleted from the smartphone device. Regarding the data that is related with driving behaviour, only the Primary Data that is recorded during a Trip is sent to the O7PLATFORM.
  5. The purposes of retaining the anonymized data in the O7PLATFORM are the following: (a) continuous improvement of the OSeven machine learning algorithms and the OSeven driving behaviour and scoring models improving the Services provided to the Users, (b) calculation of general, aggregated and fully anonymized metrics considering all the Users, regarding the driving behaviour and road safety, that can be used for (i) the improvement of the reliability of the Services provided to the Users, (ii.a) the development of anonymized and statistical driving risk indicators which (ii.b) may be communicated to the Users, (ii.c) may be published by OSeven aiming to inform, educate and improve the driving behaviour of the public (ii.d) may be communicated to public authorities to contribute to the optimum use of the available resources considering road safety and the maintenance of the road network.
    Your data (Primary Data, Driving Behaviour and Vehicle Use Data and Reward Data) will be stored in the database of OSeven and OSeven reserves the right to keep it stored, even if the Service stops or Your account becomes inactive, in compliance with the Terms and the Personal Data Privacy Policy.

6. Your rights

  1. Subject to the European General Data Protection Regulation, You retain all rights with respect to Your personal data as described in the applicable legislation. Indicatively:
    • Right to access Your personal data.
    • Right to rectification: You may request a correction to any incomplete, inaccurate or non-updated data of Yours.
    • Right to Erasure: You may request the erasure of Your personal data where there is no valid reason for OSeven to continue processing them.
    • Right to restrict the processing: You may request a restriction on the processing of Your personal data if it is inaccurate, has been used illegally, is no longer needed or in case You exercised the right to object.
    • Right to portability: You may request to receive a copy of Your personal data in a format easily re-usable or request the transmission of such data to other organizations.
    • Right to object to processing: In particular, the Services provided to You will be performed on an automated basis. In such cases, You have the right to contact Us in order to ask to be provided with information regarding the processing of Your personal data and / or to demand that Your request be examined by an OSeven official and to obtain an explanation for the automated decision taken. You should keep in mind that the access and obtaining knowledge of the automated processing, even with the assistance of an expert, may under no circumstances allow for extending this knowledge to the source code of the Application and the related algorithms.
    • Right to withdraw Your consent: Your Personal Data is processed by this Application based on Your previous consent, that You may withdraw at any time. Any such withdrawal may render Us unable to keep providing You with Our Services.
    To exercise any of Your rights, You may submit a written question to the Data Protection Officer of OSeven, Mr. Konstantinos Kakavoulis by email at dpo@oseven.io.
    However, You should keep in mind that the access and obtaining knowledge of the automated processing, even with the assistance of an expert, may under no circumstances allow for extending this knowledge to the source code of the Application and the related algorithms.
  2. Please note that in case your request related with the exercise of Your rights in the framework of EU GDPR, is abusive or manifestly unfounded or excessive, in particular because of their repetitive nature, OSeven has the right to refuse to respond to the request.
  3. In case You feel Your rights regarding Your personal data have been violated, You may file a complaint with the competent Data Protection Authority, namely the ction Authority (www.dpa.gr)
  4. Please note that you now have the right to delete your account and the associated data, following the procedure within the application. In case you request deletion of your account, please note that your data shall be fully anonymized in an irreversible way within 24 hours. We underline that the log files and the data included in them shall be retained for 30 days, as per the log files retention period.

7. How We share Your data with third parties

  1. We reserve the right to forward Your anonymized data to third parties, by using all suitable technological means, in order to ensure anonymity, except where the disclosure of Your identity to service providers is required for the execution of the Application’s purpose, in connection with the contract which supports its functions (e.g. technology services). Please note that We obligate all Our partners who legally have access to Your data to use Your data solely to perform legitimate tasks related only to the prompt and proper functioning of the Application and not for their own benefit.
  2. We transfer Your data to cloud service providers, which operate as data processors for OSeven for the retention of Your data. Such data processors are Amazon, Microsoft and Atlassian (in case of a support request) that operate as cloud service providers for the data that We retain. We ensure that the cloud servers are always located within the European Union and that the data processors implement all necessary and adequate organizational and technical measures for the protection of Your data.
  3. We also transfer Your data to Google, in the context of the operation of Google Firebase. The Application uses the following Google Firebase features to ensure the proper operation of the Application and to provide You with technical support: Firebase Cloud Messaging, Firebase Crashlytics, Firebase Remote Config, Firebase Dynamic Links. We also use the following Google Firebase features for reporting purposes: Google Analytics for Firebase (without using the data for advertising purposes). You may find information on the data collected and processed by these features here. This data may be transmitted outside the European Union and processed on global Google infrastructure. This transmission is made according to Standard Contractual Clauses, as approved by the European Commission.
  4. In connection with the above, Your data may also be forwarded to a company which has undertaken the financing of OSeven, which is merged with OSeven, acquires OSeven or its assets, in which case OSeven may continue to process Your personal data as set forth in this Privacy Policy and provided that the latter meets the requirements set forth by the applicable legislation.
  5. We reserve the right to transfer Your data to subsidiary companies of OSeven, as well as our consultants / subcontractors that work for the development / improvement / optimization of the Services provided by the Application and the O7PLATFORM. Please note that We obligate all Our consultants / subcontractors who legally have access to Your data to use Your data solely to perform legitimate tasks in compliance with the Terms and the Personal Data Privacy Policy. All our consultants/subcontractors with access to Your data are bound by legal and/or contractual clauses for the proper processing of Your data.
  6. We reserve the right to use Your data for research and development purposes or/and in the framework of research and development projects that OSeven or/and its subsidiaries may participate.
  7. We reserve the right for the publication of any data analysis by OSeven, its subsidiaries/parent companies or scientific/research partners/consultants of OSeven, provided that the published data cannot be correlated with You in any way.
  8. You should also note that We may disclose Your personal information if required to do so by court order or by decision issued by any other public authority, to the extent permitted by law.
  9. Finally, We may forward Your data to other third parties with Your explicit consent or upon Your request.
  10. We shall not sell, share, lease or exchange Your personal data, Your Primary Data, Your Driving Behaviour and Vehicle Use Data and You Reward Data, except in the cases set forth in this Personal Data Privacy Policy.

8. Handling of Your emails

Each time You send an email to Us, Your personal data is collected only to the extent necessary to respond to You and to send You Notifications which are relevant to the Application. If You have any questions regarding the processing of Your email and Your data, please do not hesitate to include them in Your email to Us.

9. Security

  1. Your personal data, which We collect, is safely stored in Our databases and We use industry standard, commercially widespread security practices, such as encryption, pseudonymization, anonymization and firewalls, to secure Your information, as per the provisions of the Terms of Use and this Personal Data Privacy Policy.
  2. However, as effective as state-of-the-art technology may be, no security system is, nor does it remain exempt from a possible attack. That is why, although We use all up-to date technology practices, We cannot fully guarantee the security of Our system, nor can We guarantee that the information You provide will not be intercepted, as it is transmitted to OSeven over the Internet at Your own risk.

10. Contact

For any inquiries regarding Your personal data, You may contact the Data Protection Officer of OSeven, Mr. Konstantinos Kakavoulis by email at dpo@oseven.io.