PRIVACY POLICY

Last Updated: August 19, 2025

This Privacy Notice for TollTracker ("we," "us," or "our") describes how and why we might access, collect, store, use, and/or share ("process") your personal information when you use our services ("Services"), including when you:

  • Visit our website at tolltracker.eu or any of our websites that link to this Privacy Notice;
  • Download and use our mobile application TollTracker or any other of our applications that link to this Privacy Notice;
  • Interact with us in other related ways, including in connection with sales, marketing, or events.

Questions or concerns? Reading this Privacy Notice will help you understand your privacy rights and choices. We are responsible for making decisions about how your personal information is processed. If you do not agree with our policies and practices, please do not use our Services.

SUMMARY OF KEY POINTS

This summary provides key points from our Privacy Notice, but you can find more details about any topic by clicking the links in the table of contents or scrolling to the relevant section.

  • What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use.
  • Do we process sensitive personal information? Some information in certain jurisdictions may be considered 'special' or 'sensitive' (e.g., ethnic origin, sexual orientation, religious beliefs). We do NOT process sensitive personal information.
  • Do we collect information from third parties? We may collect information from public databases, marketing partners, social media platforms, and other external sources.
  • How do we process your information? We process it to provide, improve, and administer the Services, to communicate with you, for security and fraud prevention, and to comply with the law.
  • In what cases and with which parties do we share personal information? We may share information in specific situations and with certain third parties.
  • How do we keep your information safe? We have appropriate organizational and technical measures in place, but no electronic transmission or storage is 100% secure.
  • What are your rights? Depending on your location, applicable law may grant you certain rights regarding your personal information.
  • How do you exercise your rights? The easiest way is to submit a data subject access request or contact us. We will review and act upon any request in accordance with applicable laws.

TABLE OF CONTENTS

1. WHAT INFORMATION DO WE COLLECT?

Personal information you provide

In short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you register for the Services, express an interest in obtaining information about us or our products and Services, participate in activities within the Services, or otherwise contact us.

Personal information provided by you. Depending on the context and your choices, this may include:

  • names;
  • phone numbers;
  • email addresses;
  • usernames;
  • passwords;
  • debit/credit card numbers;
  • billing addresses.

Sensitive Information. We do not process sensitive personal information.

Payment Data. We may collect data necessary to process payments if you choose to make purchases, such as the payment instrument number and the security code associated with it. All payment data is processed and stored by Stripe and Outseta. Their privacy policies are available here: https://stripe.com/en-bg/privacy and here: https://www.outseta.com/privacy-policy.

Social Login Data. We may provide you with the option to register/log in using an existing social network account (e.g., Facebook, X). If you do so, we will receive certain profile information such as your name, email address, friends list, and profile picture, as described in Section 6.

App Data. If you use our applications for tracking road segments for average speed, we may also collect the following information with your permission:

  • Geolocation Information. We may request access or permission to track location from your mobile device (continuously or while using the application) to provide services for tracking road segments and calculating average speed. You can change access in your device settings.
  • Push Notifications. We may request to send you push notifications regarding your account or certain features related to road segments. You can turn them off in your device settings.

All personal information you provide to us must be true, complete, and accurate, and you must notify us of any changes.

Information collected automatically

In short: Some data — such as IP address and/or browser and device characteristics — is collected automatically when you visit the Services.

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage data, such as IP addresses, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use the Services, and other technical data. This information is primarily needed to maintain the security and operation of our Services, for troubleshooting, and for internal analytics and reporting.

  • Log and Usage Data. Service, diagnostic, usage, and performance metrics automatically collected by our servers when you access the Services. This may include IP address, browser type and settings, device information, actions within the Services, device events (system activity, error reports), hardware settings, etc.
  • Device Data. Information about your computer, phone, tablet, or other device, such as IP address (or proxy), device and application identifiers, location, browser type, hardware model, internet/mobile service provider, operating system, and configuration.
  • Location Data. Data about the location of the device (precise or approximate). The amount of information collected depends on the type and settings of the device. We may use GPS and other technologies to determine location. You can opt-out by denying access or turning off the location setting on the device. Opting out may limit certain features.

Google API

Our use of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements. We may share information with certain Google Maps Platform APIs (e.g., Google Maps API, Places API) to provide location-based services.

Information collected from other sources

In short: We may collect limited data from public databases, marketing partners, social media platforms, and other external sources to improve the relevance of our offerings and records.

If you interact with us on a social platform through your social account (e.g., Facebook or X), we receive personal information about you from that platform, according to your account's privacy settings. You may have the right to withdraw your consent. Please review the settings of the respective platform.

2. HOW DO WE PROCESS YOUR INFORMATION?

In short: We process your information to provide, improve, and administer our Services, to communicate with you, for security and fraud prevention, and to comply with the law. We may also process your information for other purposes with your consent.

  • Facilitating account creation and authentication and management of user accounts to keep your account in working order.
  • Preserving or protecting the vital interests of an individual (e.g., to prevent harm).

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL DATA?

In short: We process your personal information only when we believe it is necessary and we have a valid legal basis under applicable law, such as your consent, fulfillment of contractual obligations, compliance with legal requirements, protection of vital interests, etc.

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on to process your personal information. As such, we may rely on the following legal bases:

  • Consent. We may process your information if you have given us permission for a specific purpose. You can withdraw your consent at any time.
  • Legal Obligations. We may process your information when it is necessary for compliance with our legal obligations (e.g., cooperating with a government authority, exercising or defending legal claims, evidence in court proceedings).
  • Vital Interests. We may process your information when we believe it is necessary to protect your vital interests or those of a third party.

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

In short: We may share information in specific situations and/or with the following third parties.

We may need to share your personal information in the following situations:

  • Business Transactions. We may share or transfer information in connection with, or during negotiations for, a merger, sale of company assets, financing, or acquisition of all or part of our business by another company.
  • When using Google Maps Platform APIs. We may share information with certain Google Maps Platform APIs (e.g., Maps API, Places API). Google uses GPS, Wi‑Fi, and cell towers to calculate your location. This information helps Google Maps provide directions but is not always perfectly accurate.
  • Business Partners. We may share information with our partners to offer you certain products, services, or promotions.

5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In short: Yes, we use cookies and similar technologies to collect and store information.

We use cookies and similar technologies (web beacons, pixels) to collect information when interacting with our Services. This helps us maintain security and your account, prevent crashes, fix bugs, save preferences, and support essential site functions.

We also allow third parties and service providers to use online tracking technologies in our Services for analytics and advertising, including managing and displaying ads, personalizing ads based on your interests, or abandoned cart reminders (depending on your communication preferences). These parties may use their technologies to provide ads for products and services tailored to your interests in our Services or on other sites.

Google Analytics

We may share information with Google Analytics to track and analyze usage of the Services. Google Analytics advertising features we may use include: Google Analytics Demographics and Interest Reporting, Remarketing with Google Analytics, and Google Display Network Impression Reporting.

To opt-out of Google Analytics tracking in the Services, visit the Google Analytics opt-out tool. You can opt-out of Google Analytics advertising features through Ad Settings. Other opt-out methods include NAI opt-out and NAI mobile choice. For Google's privacy practices, see Google Privacy & Terms.

6. HOW DO WE HANDLE SOCIAL LOGINS?

In short: If you choose to register or log in to our Services through a social network account, we may have access to certain information about you.

Our Services offer the ability to register/log in using third-party account details (e.g., Facebook or X). When you choose this, we receive certain profile information from the respective provider. This may vary but often includes your name, email, friends list, and profile picture, as well as other information you make public on the platform. We use the received information only for the purposes described in this Policy or which are clear to you in the respective Services. We are not responsible for other uses of your data by the social media provider. We recommend reviewing their privacy notice and setting your preferences.

7. HOW LONG DO WE KEEP YOUR INFORMATION?

In short: We store your information for as long as necessary for the purposes described in this Notice, unless a law requires otherwise.

We will store your personal information only for the period necessary for the purposes set out here, unless a longer term is required or permitted by law (e.g., tax, accounting, or other legal requirements). Nothing in this notice requires us to store personal information longer than the period during which users have an account with us.

When there is no legitimate need to process your personal information, we will delete or anonymize it, or if this is not possible (for example, because the data is in backup archives), we will securely store the personal information and isolate it from further processing until its deletion.

8. HOW DO WE KEEP YOUR INFORMATION SAFE?

In short: We strive to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate and reasonable technical and organizational measures designed to protect any personal information we process. Despite our measures and efforts to protect 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 compromise our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, the transmission of personal information to and from our Services is at your own risk. You should only access the Services in a secure environment.

9. WHAT ARE YOUR PRIVACY RIGHTS?

In short: In some regions (such as the European Economic Area (EEA), United Kingdom, and Switzerland), you have rights that allow you greater access to and control over your personal information.

In these regions, you have certain rights under applicable data protection laws. These may include the right to request: (i) access and a copy of your personal data; (ii) correction or deletion; (iii) restriction of processing; and (iv) where applicable, data portability; and (v) not to be subject to automated decision-making. You can submit such a request by contacting us using the details in Section 12. We will review and act upon any request in accordance with applicable law.

If you are in the EEA or UK and believe we are unlawfully processing your personal information, you have the right to lodge a complaint with your national supervisory authority or the ICO (UK). In Switzerland, you can contact the Federal Data Protection and Information Commissioner.

Withdrawal of Consent

If we rely on your consent, you can withdraw it at any time by contacting us (see Section 12). This will not affect the lawfulness of processing before the withdrawal, nor processing on another legal basis other than consent.

Unsubscribing from marketing communications

You can unsubscribe from our marketing and promotional communications at any time by clicking the unsubscribe link in the emails sent or by contacting us (see Section 12). We may continue to send you service-related communications (e.g., important account notifications).

Account Information

To review or change the information in your account or to close your account, you can:

  • Log in to your account settings and update user data; or
  • Contact us via the contact information below.

Upon request to close the account, we will deactivate or delete the account and information from active databases. We may retain some information in our files to prevent fraud, troubleshoot, assist with investigations, enforce our legal terms, and/or comply with applicable legal requirements.

Cookies and similar technologies: Most web browsers accept cookies by default. If you prefer, you can usually set your browser to remove or reject cookies. Refusal may affect certain features of the Services.

10. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and applications include a 'Do-Not-Track' (DNT) feature or setting that you can activate to signal your preference not to have your online activities tracked. At this stage, a unified standard for recognizing and applying DNT signals has not been finalized. Therefore, we currently do not respond to DNT signals or any other mechanism that automatically communicates your choice not to be tracked online. If an online tracking standard is adopted that we must follow in the future, we will notify you in a revised version of this Notice.

11. DO WE MAKE UPDATES TO THIS NOTICE?

In short: Yes, we will update this notice as necessary to remain in compliance with applicable laws.

We may update this Privacy Notice periodically. The updated version will be indicated by 'Revised' and an updated date at the top. If we make significant changes, we may notify you by posting a notice or by sending a direct notification. We encourage you to review this Notice often to stay informed about how we protect your information.

12. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

For questions or comments about this notice, write to [email protected] or by mail to:

TollTracker Sofia, Bulgaria

If you are a resident of the European Economic Area, we are the 'data controller' for your personal information. We have appointed Viktor Kolev as our EEA representative. You can contact him directly regarding the processing of your information at email [email protected].

13. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

You have the right to request access to the personal information we collect from you, details about how we have processed it, to correct inaccuracies, or to delete your personal information. You may also have the right to withdraw your consent. These rights may be limited in certain cases by applicable law. To submit a request to review, update, or delete your personal information, please send an email to [email protected] with the subject 'Data Subject Access Request'.

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