PRIVACY POLICY

Effective Date: August 12, 2025
Last Updated: August 12, 2025

1. DATA CONTROLLER AND CONTACT INFORMATION

Data Controller: Moesia VCC
UIC: 208426032
Address: 28 Bratya Miladinovi Str., Floor 6, Apt. 16, Varna, Bulgaria
Email: privacy@vozyme.com
Support: support@vozyme.com

This Privacy Policy explains how we collect, use, and protect your personal data when using the Vozyme ridesharing marketplace platform.

2. WHAT DATA WE COLLECT (DATA MINIMIZATION)

2.1 Personal Information We Collect

We collect only the minimum data necessary for platform operation:

Account Data:

• Email address (for account creation and communication)
• First and last name
• Phone number (required only for ride publication verification)

Platform Usage Data:

• Ride history (published and booked rides)
• Ride requests (dates, start/end locations)
• Ratings and reviews between users
• Messages between users for ride coordination
• Basic platform usage analytics (anonymized)
• Technical logs for security and debugging

2.2 What We DO NOT Collect

We explicitly DO NOT collect:

• Real-time location tracking during rides
• Payment card information (platform is free during MVP period)
• Driver's license information
• GPS tracking of actual routes
• Social media data
• Biometric data
• Financial information for transactions between users

3. LEGAL BASIS FOR PROCESSING (GDPR COMPLIANCE)

We process your data based on:

• Contract Performance (providing access to the marketplace platform)
• Legitimate Interests (platform security, fraud prevention)
• Explicit Consent (where specifically requested for additional features)
• Legal Obligations (compliance with Bulgarian/EU law)

4. HOW WE USE YOUR DATA

4.1 Primary Uses

Your data is used exclusively for:

• Creating and managing your platform account
• Enabling communication between users for ridesharing
• Basic algorithmic matching of ride requests
• Platform security and fraud prevention
• Legal compliance and safety investigations when necessary

4.2 What We DO NOT Do With Your Data

EXPLICIT COMMITMENTS:

• DO NOT sell your personal data to third parties
• DO NOT use your data for advertising purposes
• DO NOT share data with marketing companies
• DO NOT track your location outside the platform

5. DATA SHARING (STRICT LIMITATIONS)

We share personal data only in these limited circumstances:

With Other Users (Minimal Disclosure):

• Name when publishing or responding to rides
• Basic contact information necessary for ride coordination

With Service Providers:

• Cloud hosting providers (with appropriate data processing agreements)
• Email service providers (for platform communication)
• Push notifications: Expo Push Service (APNs/FCM)

6. DATA STORAGE AND SECURITY

6.1 Data Location

• Primary data storage: European Economic Area (EEA)
• No data transfers outside EEA without appropriate safeguards

6.2 Data Retention

• Active accounts: Data retained while account is active
• Ride history: 2 years after ride completion
• Messages: 1 year after last message in conversation
• Ratings: Permanent retention (part of trust system)
• Deleted accounts: Anonymized within 30 days
• Technical logs: 90 days for security and debugging

7. YOUR RIGHTS UNDER GDPR

7.1 Individual Rights

You have the right to:

• Access your personal data and processing information
• Rectify inaccurate or incomplete data
• Delete your data (right to be forgotten)
• Restrict processing under specific circumstances
• Data Portability in machine-readable format
• Object to processing based on legitimate interests
• Withdraw Consent where processing is based on consent

7.2 Exercising Your Rights

To exercise these rights:

• Contact us at privacy@vozyme.com
• We will respond within 30 days
• Identity verification may be required

8. ACCOUNT DELETION AND DATA HANDLING

When you delete your account:

1. Immediate cessation of data processing for platform services
2. Soft deletion of personal identifiers within 30 days
3. Anonymization of ride history data
4. Retention of anonymized data for legitimate business purposes

9. CHILDREN'S PRIVACY

• The platform is intended for users 18 years and older
• We do not knowingly collect data from minors
• Accounts created by minors will be terminated

10. COOKIES AND TRACKING

Mobile Application: Does not use cookies. Authentication tokens are stored in the app's secure storage.

Web Application: We minimize browser storage. Details in our Cookie Policy.

10.1 No Tracking Cookies

We DO NOT use:

• Advertising cookies
• Cross-site tracking
• Third-party marketing cookies

11. AUTOMATED DECISION-MAKING AND PROFILING

• We use algorithmic matching to suggest relevant rides based on origin/destination/date
• These processes do not produce legal or similarly significant effects on you
• You may contact us to obtain human review or to object to automated outputs

12. CONTACT AND QUESTIONS

Privacy Officer: privacy@vozyme.com
General Contact: support@vozyme.com
Address: Moesia VCC, 28 Bratya Miladinovi Str., Floor 6, Apt. 16, Varna, Bulgaria
UIC: 208426032

Response Time: We aim to respond to privacy inquiries within 5 business days.

PRIVACY COMMITMENT SUMMARY

Our Core Privacy Principles:

• We collect only necessary data for platform operation
• We never sell user data
• We are transparent about current and planned features
• We respect user rights and choices
• We implement strong security measures
• We comply with Bulgarian and EU data protection law

By using Vozyme, you acknowledge that you have read and understood this Privacy Policy.