AIOTI TECNOLOGIA LTDA. PRIVACY POLICY
SafePilot Platform
1. COMPANY IDENTIFICATION
This Privacy Policy applies to the services provided by AIOTI TECNOLOGIA LTDA., a Brazilian limited liability company registered with the CNPJ under No. 55.683.959/0001-60, hereinafter referred to as “Aioti”.
Aioti develops and provides the SafePilot Platform, a technology solution designed to monitor driving behavior through mobile telematics with the aim of reducing the risk of traffic accidents.
2. APPLICABILITY AND ACCEPTANCE
This Privacy Policy applies to all users of the SafePilot Platform, including fleet managers and drivers, as well as companies that contract the services. Use of the Platform constitutes full acceptance of this Policy and the corresponding Terms of Use.
Aioti acts as the controller of personal data collected through the SafePilot Platform under Brazil’s General Data Protection Law (Lei Geral de Proteção de Dados Pessoais — Law No. 13,709/2018, “LGPD”).
3. PERSONAL DATA COLLECTED
3.1 Contracting Company Data
When the SaaS services are contracted, Aioti collects standard information about the contracting company, including its legal name, CNPJ, address, contact details, and information about the person responsible for operating the system.
3.2 Fleet Manager Data
To register a fleet manager, Aioti collects the manager’s full name, email address, and telephone number.
3.3 Driver Data
Driver registration includes the driver’s full name, telephone number, assigned fleet identifier, vehicle category, and email address when available.
3.4 Telemetry and Driving Behavior Data
The SafePilot Platform automatically collects the following driving behavior data through the mobile application:
- Harsh acceleration events;
- Harsh braking events;
- Sharp cornering events;
- Speed data and comparisons with applicable road speed limits;
- Detection of mobile phone use while driving;
- Location and route data;
- Trip times and duration;
- Mobile device information required for the system to operate.
3.5 Browsing and Usage Data
Aioti collects information about use of the web platform and mobile application, including access logs, IP addresses, and device and operating system information.
4. PURPOSES OF PROCESSING
The personal data collected is used exclusively for the following purposes:
4.1 Provision of Services
Operation of the SafePilot Platform, including monitoring driving behavior, processing telemetry data, and generating fleet management reports.
4.2 Communications with Users
Sending notifications, feedback on driving behavior, safety alerts, and communications related to operation of the Platform.
4.3 Scoring and Ranking System
Creating and maintaining driver scoring and ranking systems with privacy settings determined by the fleet manager.
4.4 Service Improvement
Analyzing aggregated and anonymized data to improve the Platform and develop new features.
4.5 Compliance with Legal Obligations
Meeting legal and regulatory requirements and responding to competent authorities.
5. LEGAL BASES FOR PROCESSING
Aioti processes personal data under the following legal bases provided by the LGPD:
- Performance of a contract (art. 7, V): for data required to provide the contracted services;
- Legitimate interest (art. 7, IX): to improve services and conduct statistical analyses;
- Consent (art. 7, I): when applicable and expressly requested.
6. DATA SHARING
6.1 General Policy
Aioti does not sell personal data and maintains a strict confidentiality policy. Data is shared only in the circumstances described in this Policy.
6.2 Disclosure of Statistical Data
Aioti may publish statistical data in the media concerning results achieved in reducing accidents. Such data must always be anonymized and must not allow any individual or specific company to be identified.
6.3 Case Studies
Case studies concerning specific companies shall be prepared and disclosed only with the contracting company’s express authorization.
6.4 Service Providers
Data may be shared with technology service providers, including cloud providers, exclusively to operate the Platform and always under agreements that ensure adequate data protection.
6.5 Legal Requirements
Data may be shared when required by law, court order, or a request from a competent authority.
7. INTERNATIONAL DATA TRANSFERS
Data may be processed on cloud servers located outside Brazil in compliance with applicable data protection standards. International transfers may be made to countries such as the United States or Member States of the European Union through cloud providers that offer adequate data protection safeguards, including standard contractual clauses and compliance with the General Data Protection Regulation (GDPR).
All international transfers are based on appropriate protection safeguards as required by the LGPD.
8. DATA SECURITY
Aioti adopts strict technical and organizational measures to protect the confidentiality, integrity, and security of personal data, including:
- Role-based access controls;
- Secure authentication systems;
- Continuous application monitoring;
- Encryption of data in transit and at rest;
- Backup and recovery procedures;
- Regular employee training on data protection.
9. DATA RETENTION
Personal data is stored throughout the contractual relationship with the contracting company and for any additional period required for legal, technical, or audit purposes.
After the required retention period ends, data is anonymized and may be retained for internal artificial intelligence training purposes. Identifiable data is securely and irreversibly deleted from Aioti’s systems in accordance with information security best practices.
10. COOKIES AND TRACKING TECHNOLOGIES
The SafePilot Platform uses cookies and similar technologies for the following purposes:
10.1 Essential Cookies
These cookies are required for the basic operation of the web platform, including authentication and session maintenance.
10.2 Analytics Cookies
These cookies are used to analyze usage and improve the user experience on the web platform.
10.3 Preference Management
Users are informed about the use of cookies through a banner or initial notice in the web portal and may manage their preferences through browser settings or the Platform’s specific Cookie Policy.
11. DATA SUBJECT RIGHTS
SafePilot Platform users have the following rights concerning their personal data:
11.1 Right of Access
Obtain information about the personal data processed by Aioti.
11.2 Right to Correction
Request the correction of incomplete, inaccurate, or outdated data.
11.3 Right to Deletion
Request deletion of data processed on the basis of consent or when the data is no longer required for the purposes for which it was collected.
11.4 Right to Data Portability
Obtain a copy of personal data in a structured and commonly used format.
11.5 Right to Information
Receive information about the sharing of data with third parties.
11.6 Right to Withdraw Consent
Withdraw consent when consent is the legal basis for processing.
11.7 Exercising Your Rights
To exercise any of these rights, the data subject must submit a request to aiotitecnologialtda@gmail.com, providing information that enables identification and clearly specifying the request.
12. MARKETING AND PROMOTIONAL COMMUNICATIONS
Aioti uses personal data for direct marketing and promotional communications relating to its services. Users may opt out of these communications at any time through the available contact channels.
13. RELATIONSHIP BETWEEN THE PARTIES
Aioti has a direct contractual relationship exclusively with the company that contracts the services. Drivers do not have a direct contractual relationship with Aioti and use the Platform as end users through their employer.
14. SECURITY INCIDENTS
If a security incident may create a relevant risk or harm to data subjects, Aioti shall follow a specific protocol that includes:
- Immediate identification of the event;
- Containment of the incident;
- Assessment of the impact on data and data subjects;
- Notification of affected users, when applicable;
- Notification of Brazil’s National Data Protection Authority (Autoridade Nacional de Proteção de Dados — ANPD), as required by the LGPD;
- Implementation of corrective and preventive measures.
15. CHANGES TO THIS POLICY
This Privacy Policy may be updated periodically to reflect changes to the services, applicable law, or data protection practices. Material changes shall be communicated to users through:
- Email messages sent to registered addresses;
- Notifications in the SafePilot application;
- Notices in the Platform’s web portal.
Users should review this Policy periodically to remain informed about any updates.
16. GOVERNING LAW
This Privacy Policy is governed by Brazilian law, particularly the General Data Protection Law (Law No. 13,709/2018), the Brazilian Civil Rights Framework for the Internet (Law No. 12,965/2014), and other applicable regulations.
17. EFFECTIVE TERM
This Privacy Policy becomes effective on its publication date and remains valid indefinitely until replaced by a new version.
Last updated: August 5, 2025