Mobile Applications Privacy Notice

1. Who we are

This policy is issued by the following Road Angel Group companies:

The company named as the developer or publisher in the relevant app-store listing identifies the Road Angel Group company responsible for publishing that app. Depending on the product, account, subscription or connected service, In Phase International Ltd and Space Data Centres Ltd may act as separate controllers, joint controllers or as a controller and service provider.

Where necessary, we will explain which Road Angel Group company is responsible for a particular processing activity. You may also ask us by emailing privacy@roadangelgroup.com .

2. Apps covered by this policy

This policy applies to the following applications:

This policy also applies to an updated, renamed or replacement Road Angel application where that application links to this policy.

3. What access, collection and sharing mean

For the purposes of this policy:

• Access: means that an app can read or use information on your phone or connected Road Angel product. Access may take place locally without the information being sent to Road Angel.
• Collection: means information is transmitted from the app, phone or connected product to Road Angel or to a provider acting for us.
• Sharing: means information is made available to another organisation for its own purposes or as necessary to provide a service.

An app may access information locally without Road Angel collecting that information. For example, a dash-cam app may access a recording over a direct Wi-Fi connection so that you can view or download it without the recording being automatically sent to our servers.

4. Information used by each app

5. Categories of information we may use

5.1 Account and contact information

• Name;
• Email address;
• Telephone number;
• Postal or billing address where required;
• Account username and customer reference;
• Protected password or authentication information;
• Account preferences;
• Marketing preferences; and
• Information needed to verify your identity.

5.2 Product, vehicle and connected-device information

• Product type, model and serial number;
• Firmware and software version;
• Activation, registration and installation date;
• Vehicle registration, make and model where relevant;
• Installer or dealer details;
• Product configuration and settings;
• Battery, power and connectivity status;
• Subscription and warranty status;
• Device ownership and linked-account information; and
• Diagnostic, fault and technical information.

Where we process an IMEI, SIM telephone number or SIM identifier, this will normally relate to a connected Road Angel tracker or other Road Angel hardware. Such identifiers are used to identify, activate, communicate with and support the connected product. They are not used for advertising.

5.3 App and phone information

• Phone manufacturer and model;
• Operating-system version;
• App version;
• Language, time zone and regional settings;
• IP address;
• App installation or instance identifier;
• Push-notification token;
• Login date and time;
• Features used and screens viewed;
• Crash, error, performance and diagnostic information; and
• Security and fraud-detection information.

5.4 Location and journey information

• Approximate or precise phone location where permission is granted;
• Location generated by a connected Road Angel tracker or device;
• Journey start and end points;
• Route and journey history;
• Date and time information;
• Speed, direction, movement and distance;
• Geofences and location-based alerts;
• Dash-cam GPS data where present; and
• Location-sharing permissions and authorised recipients.

5.5 Orders, subscriptions and transactions

• Products and services purchased;
• Subscription type, status and renewal date;
• App-store purchase or subscription confirmation;
• Payment status;
• Refund, cancellation and renewal information; and
• Invoices and transaction references.

Complete payment-card details are normally handled directly by the app store or an authorised payment provider. We do not ordinarily receive or retain the full card number.

5.6 Support and communications

• Support requests and correspondence;
• Complaint details;
• Photographs, videos, logs or screenshots submitted by you;
• Telephone-call records or recordings where applicable;
• Diagnostic files supplied for troubleshooting; and
• Actions taken to resolve an issue.

6. App permissions

An app will only request permissions relevant to its current functions. Permissions can be controlled through the settings on your phone. Refusing or withdrawing a permission may prevent the related feature from working.

Some older versions of Android may require location permission to discover a nearby Bluetooth or Wi-Fi device even when the feature does not use your location for tracking.

7. Location information

7.1 Phone location

The Road Angel app may use your phone’s approximate or precise location when you activate a location-based feature, such as map display, driving alerts or location-dependent safety information.

Where a feature requires continuous location access while the app is not visible, the app will provide a prominent explanation before requesting background-location permission. The explanation will identify the location information used and the feature for which it is needed.

You may refuse or withdraw location permission through your phone settings. Features that depend on location may then be unavailable or may not work correctly.

7.2 Connected tracker or device location

Halo Secure and relevant connected services may display location generated by a Road Angel tracker or another linked device. This may include live position, historic routes, time, speed, direction, movement, distance and geofence events.

Connected-device location can continue to be generated while the tracker or connected product is active, even where the Halo Secure app is closed. This is because the location originates from the connected product and is made available through the customer’s account.

7.3 Location sharing

Where Halo Secure permits location sharing, the account holder controls which invited users can view the relevant device. The account holder should only invite people who are authorised to receive that information and should remove access when it is no longer needed.

We may disclose location information to a monitoring centre, recovery provider, insurer, police or other lawful authority where this is necessary to respond to theft, protect people or property, comply with law, investigate misuse or provide the service requested.

We do not sell precise location information or use it for third-party behavioural advertising.

8. Dash cams, photographs, video and audio

Road Angel Halo, Halo Playback and compatible features within the Road Angel app allow you to connect to a dash cam, view live video, play recordings, change settings and download selected footage.

8.1 Local access

Where the app connects directly to the dash cam through a local Wi-Fi connection, the footage remains on the dash cam unless you choose to view, download, save, upload or share it. Merely viewing footage over the local connection does not automatically upload it to Road Angel.

8.2 Downloading and sharing

When you download footage, a copy may be stored on your phone. If you choose to share it, the selected recording may be transferred to the person, app or service that you select. That recipient may process the footage under its own privacy terms.

8.3 Cloud or support uploads

If you enable an available cloud feature or deliberately upload footage for customer support, incident review, warranty, recovery or another requested service, the selected footage will be transmitted to Road Angel or an authorised provider for that purpose.

8.4 Other people appearing in footage

Dash-cam footage may contain images, voices, vehicle registrations and locations relating to other people. You are responsible for using and sharing footage lawfully. You should take particular care before publishing footage publicly or sharing it for a purpose unrelated to an incident, insurance claim, police report or other legitimate need.

9. Why we use information and our lawful bases

Where we rely on legitimate interests, we consider the necessity of the processing, the expected benefit and the possible impact on your rights.

10. Who may receive information

We do not sell personal information.

We may provide relevant information to the following recipients where necessary:

• In Phase International Ltd and Space Data Centres Ltd;
• App-store and operating-system providers, including Google and Apple;
• Cloud-hosting and data-storage providers;
• Mapping and location-service providers, including HERE where integrated;
• Push-notification providers;
• App analytics, diagnostic and crash-reporting providers;
• Authentication and cybersecurity providers;
• Payment, subscription and billing providers;
• CRM and customer-support providers;
• Dash-cam, tracking, firmware and connected-product technology providers;
• Authorised retailers, dealers, installers and vehicle manufacturers;
• Monitoring centres and vehicle-recovery providers;
• Insurers, fleet operators and finance providers where relevant;
• Police, emergency services, courts, regulators and other lawful authorities;
• Solicitors, accountants, auditors and professional advisers; and
• A buyer or successor if all or part of the business is sold or reorganised.

Providers acting for us are only permitted to use information for the agreed service, subject to appropriate contractual, confidentiality and security requirements.

Where you use an app’s share function, information may also be provided to the individual, social-media service, messaging service, insurer, police force or other recipient selected by you.

11. International data transfers

Some app, cloud, mapping, diagnostic or support providers may process information outside the United Kingdom or European Economic Area.

Where required, we use a legally recognised transfer mechanism, such as:

• UK adequacy regulations;
• European Commission adequacy decisions;
• The UK International Data Transfer Agreement;
• The UK Addendum to the European Commission Standard Contractual Clauses;
• Standard Contractual Clauses; or
• Another legally recognised safeguard.

You may request further information about the safeguard relevant to your information by contacting us.

12. How long we retain information

We retain personal information only for as long as reasonably necessary for the relevant app, product, subscription or service. Retention depends on the nature of the information, whether an account or service remains active, legal requirements, complaints, fraud, security incidents and legal claims.

At the end of the applicable period, information will be securely deleted, anonymised or isolated where deletion is not immediately possible.

13. How we protect information

We use technical and organisational measures designed to protect app and connected product information against accidental loss, unauthorised access, misuse, alteration or disclosure.

Measures may include:

• Encrypted connections for personal and sensitive information transmitted over the internet;
• Account authentication and password controls;
• Role-based access permissions;
• Access logging and monitoring;
• Network and infrastructure security;
• Supplier security reviews and contractual controls;
• Secure software-development practices;
• Vulnerability and incident-management procedures;
• Staff confidentiality and data-protection training;
• Backup and recovery controls; and
• Physical security at relevant premises.

A direct Wi-Fi connection between a phone and dash cam is normally a local device-to-device connection rather than an internet transmission. You should use suitable phone security and avoid connecting to an unknown or unauthorised device.

No system can guarantee complete security. Please use a strong, unique password, protect access to your phone and contact us promptly if you believe your account or connected device has been compromised.

14. Your controls and choices

14.1 Device permissions

You can grant, refuse or withdraw app permissions through your phone settings. Withdrawing a permission may stop the relevant function from working.

14.2 Notifications

You can manage app notifications through the app or phone settings. Certain operational, security, subscription or legal communications may still be sent by email, SMS or another available channel where necessary.

14.3 Marketing

You can stop marketing emails by using the unsubscribe link or by contacting us. Marketing preferences do not prevent necessary service, safety, theft, security, subscription or account messages.

14.4 Location sharing

The Halo Secure account holder can manage invited users, linked devices, geofences and sharing permissions through available account controls.

14.5 Dash-cam footage

You decide whether to download, save, upload or share footage accessed through a local dash-cam connection.

15. How to delete your app account and associated data

15.1 Information to include

Please provide:

• The app name;
• Your full name;
• The email address used for the account;
• Your telephone number if registered;
• The relevant device or product serial number, where available; and
• Whether you want to delete the entire account or only specified app information.

We may request reasonable information to verify your identity and protect the account from an unauthorised deletion request.

15.2 What will normally be deleted

Subject to legal exceptions, deletion may include:

• Your app profile and account credentials;
• App preferences;
• Push-notification tokens;
• Linked-device access associated only with the deleted account;
• Location and journey information associated with the account;
• Geofences and location-sharing permissions;
• Optional app-activity and diagnostic information that remains identifiable; and
• Other personal information that is no longer required.

15.3 Information we may retain

We may retain limited information where necessary for:

• Tax, accounting and transaction-record obligations;
• Fraud prevention and account security;
• An active theft or vehicle-recovery incident;
• An insurance claim, complaint or dispute;
• Compliance with a court order or legal obligation;
• The establishment, exercise or defence of legal claims;
• Product safety or warranty evidence; or
• A minimal marketing-suppression record.

Retained information will be restricted to the relevant purpose and will not be kept for ordinary app use.

15.4 Subscriptions and connected services

Account deletion may unlink products, remove access to journey history and disable connected features. Where a product is being transferred to another person, please contact support before deleting the account.

15.5 Timescale

We will normally respond within one month after receiving a valid request and any information reasonably needed to verify it. A longer period may apply where permitted by law because a request is complex or numerous.

Simply uninstalling an app does not delete the account or information already held by Road Angel.

16. Your data-protection rights

Depending on the circumstances and applicable law, you may have the right to:

• Request access to your personal information;
• Request correction of inaccurate information;
• Request completion of incomplete information;
• Request deletion of personal information;
• Request restriction of processing;
• Object to processing based on legitimate interests;
• Object to direct marketing;
• Withdraw consent at any time where processing is based on consent;
• Request transfer of qualifying information;
• Request information about international-transfer safeguards; and
• Complain to a supervisory authority.

These rights are not absolute and may be subject to legal conditions or exemptions.

To exercise a right, email privacy@roadangelgroup.com .

17. Automated systems

We do not ordinarily make decisions producing legal or similarly significant effects solely through automated processing.

Automated systems may be used to:

• Generate location, movement, geofence, speed or battery alerts;
• Detect unusual account or device activity;
• Identify technical faults;
• Prioritise security or support issues;
• Detect suspected fraud or misuse; and
• Provide relevant product or service messages.

18. Children

Road Angel apps and connected services are not directed at children under 16. We do not knowingly create accounts for children under 16 or intentionally collect their personal information without an appropriate lawful basis and, where required, parental or guardian involvement.

Please contact us if you believe that a child has provided personal information through one of our apps without appropriate authority.

19. Third-party services and links

An app may contain links to an app store, payment provider, mapping provider, support service, social-media service or other independent third party.

Where you choose to interact directly with an independent third party, its own privacy terms will apply to the information it receives. Road Angel remains responsible for information that Road Angel itself collects and processes.

An embedded webpage or account portal may use cookies or similar technologies. Further details are provided in our Privacy & Cookie Policy .

20. Changes to this policy

We may update this policy to reflect changes to our apps, products, connected services, suppliers, technology, legal requirements or data-handling activities.

The latest version will be published on this page with an updated revision date. Where a change materially affects how we use personal information, we may also provide an in-app, email or other appropriate notice.

21. Contact details and complaints

Please contact us first if you have a concern about our use of your information.

You also have the right to complain to the UK Information Commissioner’s Office: ico.org.uk/make-a-complaint .

If you are located in the European Economic Area, you may also complain to the data-protection authority in the country where you live or work.