Privacy Policy Policy App Subscription Dongle REMOTO REMOTO Package Bright Box Hungary Korlátolt Felelősségű Társaság Bright Box our Group

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1 Privacy Policy This Privacy Policy ( Policy ) applies to your use of the REMOTO telematics based mobile phone application (the App ) whose features are made available to you on a subscription basis (the Subscription ) as well as the installation of a telematics device that is connected to your vehicle (the Dongle ) (collectively REMOTO or the REMOTO Package ). REMOTO is provided by Bright Box Hungary Korlátolt Felelősségű Társaság (company number ) whose registered address is 1132 Budapest, Váci út , Hungary ( Bright Box, we, us, and/or our ). This Policy explains how REMOTO collects, uses, discloses and otherwise processes personal information about you, when you use REMOTO and, for these purposes, Bright Box will be the data controller and Bright Box will be processing such data as our data processor. Bright Box may also anonymise your personal information so that it can use such anonymous data to improve REMOTO. The information you provide to us through the use of REMOTO may then be shared with other companies within the Bright Box group, including subsidiary companies, affiliates (the Group ). Depending on your relationship with Bright Box, we may also provide or may have already provided you with other notices about our use of your personal information, for example in relation to your purchase of a certain model of vehicle or the purchase of other products and/or services on our website Those notices, if applicable, are not replaced by this Policy and are therefore still in effect. 1. What types of information does REMOTO collect and why? 1.1 When a Dongle is connected to your vehicle, we may collect the following categories of information (nb some of these categories will be relevant to post-launch versions of REMOTO): your Vehicle Identification Number, or VIN (which is associated with other information about you) its brand, model and year of manufacture and purchase; details of your vehicle s general performance, including engine efficiency and health, mileage, tyre pressure, battery status; details of the mobile device to which the Subscription is linked via the App; GPS data to determine the location of you, your vehicle and/or your mobile device, relative to the location of your vehicle, including the relevant city and country in which each are located (provided, where required by applicable law, your prior consent has been given, or there is some other lawful reason to process this personal data); your speed of travel in your vehicle, including average speed, parking duration, incidents of heavy braking, incidents of rapid acceleration and incidents of exceeding 130km/h; and an analysis of the journey undertaken in your Vehicle, including average speed, distance travelled, parking time, events (such as exceeding any self-set speed limit). 1.2 In addition to the above, when using REMOTO, REMOTO may also collect the following information, in addition to and (where appropriate) in connection with, the above noted information: your name and contact details; for example, your address, postal code, country, telephone numbers and/or address; and The above information (either on its own or in combination with other information we hold about you) may allow us to identify you as an individual. This type of personal information is called personal data. Where such personal data is collected by App, we will process that information for the purposes described in this Policy. 1.4 Where you contact us in relation to REMOTO, we may also collect the following personal data from you: your name and contact details; for example, your address, postal code, country, telephone numbers and/or address; the reason for your contact; information about services that interest you; and/or information necessary for legal compliance. 1.5 This information will be collected primarily from you but we may also collect it, where lawful to do so, from and combine it with information which we may already hold about you, from public sources, third party service providers, government, tax and/or law enforcement agencies, and other third parties. We may also collect personal data about you from your use of our other Group company services. 2. How does Bright Box use your personal data? 2.1 We may use information described in paragraph 1 for the following purposes: to respond to and/or deal with your request or enquiry; to improve the functionality and quality of REMOTO;

2 2.1.3 to administer REMOTO when you have an active Subscription, which may include (amongst others): to book a insurance request, credit request, call-back request, suggestion and complains request, test drive and/or servicing of your vehicle or (in the case of test drive) a potential replacement your vehicle, which is then linked to the calendar on your mobile device; to enable you to locate nearby car maker s offices and contact them via the App; to locate your vehicle and/or inform you when your vehicle moves out of a certain location or is moving when the engine is turned off; to enable you to share your location with car maker or third parties (such as roadside assistance); to enable you to geo-fence your vehicle and be notified if your vehicle should travel outside the fenced area; to inform you of the health of your vehicle, including issues related to your vehicle s engine, tyre pressure and battery life; to enable you to contact roadside assistance; to notify you when your vehicle exceeds any self-set speed limit; to analyse any recent trips taken in your vehicle, including notification of when it travels above a self-set speed limit; to enable us to identify whether your contact information has come to us via the App (rather than another means of contact); and to satisfy any requests you may make via the App (e.g. a service request); to notify car maker branches of any upcoming services, test drives or other appointments in relation to you or your vehicle; for internal record keeping; to assist with customer enquiries or complaints in relation to REMOTO, and the development of new, relevant services; to contact you (directly, either by car maker or by the Group or through a relevant partner or agent, including Bright Box) by , text or push notification, for any of the above reasons (which excludes marketing communications); to carry out direct marketing (either by , post, phone, text, directly through the App or via other means); to provide you with information regarding Bright Box or car maker special offers that are generally available to all REMOTO customers with an active Subscription; to inform you of news and updates on Bright Box, its partners and their various product offerings; where necessary as part of any restructuring or sale of Bright Box or a relevant Group company s business or assets; to perform any contract Bright Box has with you; for compliance with legal, regulatory and other good governance obligations; and for any other purposes related to the management of your legal relationship with Bright Box. Where we are required by applicable law to obtain your prior consent in order to process your personal data for the purposes described above, we will do so. The above list may be updated from time to time as Bright Box s business needs and legal requirements dictate. In the event that this Policy is updated, we will provide you with notice of this update as may be required by applicable law. 2.2 Please be aware that as REMOTO is improved and updated over time, we may need to process your personal data in ways different to those listed above. Whenever this is the case, we will update this Policy in accordance with paragraph 10 (below). 2.3 Subject to applicable law, we may also process your personal data for other legitimate business purposes including but not limited to management analysis, audit, forecasts, business planning and transactions, ensuring our compliance with applicable laws, regulatory requirements and Bright Box policies, dealing with legal claims and related investigatory and/or administrative activities and any applicable record retention obligations. We may also process it to establish or exercise our legal rights and to comply with law enforcement or other government agency requests or court orders. 2.4 Please be aware that while a Dongle is connected to your vehicle, we may continue to process some of your personal data for the purposes described above, including when your Subscription has expired. Therefore, if you no longer wish for Bright Box to process such Personal Data, please arrange to have the Dongle disconnected or deactivated by your local car maker office or supplier. 2.5 Bright Box may also convert personal data into anonymous data and use it (normally on an aggregated statistical basis) for research and analysis to improve REMOTO. For more information, please see the Aggregated Information section, below.

3 3. Aggregated Information Aggregated personal information does not personally identify you or any other user of REMOTO. It may be used for statistical analysis and administration, including but not limited to, analysis of trends, carrying out actuarial work, tailoring products, risk assessment and analysis of associated costs in relation to the operation of REMOTO. 4. Does Bright Box share personal data with third parties? 4.1 Your personal data will be made available for the purposes mentioned above (or as otherwise notified to you from time to time and where there is a lawful reason to do so, in compliance with applicable law), not only within Bright Box Group but also with car maker Group, our third party service providers, including Bright Box (as noted above). 4.2 REMOTO will also be provided by use of Microsoft Azure, which is a cloud based infrastructure hosted by Microsoft as part of their Office 365 offering. Accordingly, in order to provide you with REMOTO, Microsoft will process your personal data for and on behalf of Bright Box, as our data processor under contract with Bright Box. 4.3 Your personal data may also be made available to other third parties (within or outside the Group) providing relevant services under contract to Bright Box Group (see below for further details), such as Bright Box s own or third party software developers, providers of support and other services, auditors and/or compliance managers, IT hosting and/or IT maintenance providers and/or other third party agents. These companies may use information about you to perform their functions on our behalf. 4.4 As part of REMOTO, your personal data may be shared with those third party organisations who assist Bright Box to provide roadside assistance, or roadside accident/emergency support. Please note that your personal data will only be transferred to these third parties where their assistance is required, and your personal data will not otherwise be provided to them as a matter of course. For a full list of the organisations who provide this support, please see the information relevant to your jurisdiction in the list provided Annex We may disclose specific information upon lawful request by government authorities, law enforcement and regulatory authorities where required or permitted by law and/or for tax or other purposes. Subject to applicable law, personal data may also be released to external parties in response to legal process, and when required to comply with laws, or to enforce our agreements, corporate policies, and/or terms of use or supply, or to protect the rights, property or public safety, or protect you or Bright Box. 5. Will your personal data be transferred abroad? 5.1 Your personal data may be processed in or accessed from jurisdictons outside the European Economic Area ( EEA ) by members of the Group or our service providers (such as Microsoft and Bright Box), which are not based within the EEA. Accordingly, for those individuals with a connected Dongle and/or using REMOTO within Europe, you should be aware that such recipients of your personal data may be located in countries or territories outside the EEA which may not have adequate data protection laws equivalent to those within the EEA. In those cases, steps will be taken to protect your rights and personal data as required by applicable law. 5.2 Individuals in other regions may also have their personal data transferred outside of their own country by Bright Box or one of our service providers. By consenting to the connection of a Dongle and/or the activation of a Subscription, and subject to any other requirements of applicable law, this will also act as your consent to the transfer of your personal data as set out in this Policy. 6. What choices does Bright Box offer you with regard to direct marketing? 6.1 We may wish to provide you with information about new products, services, promotions and offers from Bright Box and/or the Group and third parties, which may be of interest to you, and may invite you to take part in market research or request feedback on Bright Box and/or car maker Group and third party products and services (including but not limited to REMOTO). This communication may occur by post, , SMS and/or telephone. Where we are required to do so, we will obtain your prior consent to contact you in this way in accordance with applicable law. 6.2 If required by applicable law, we will ensure that any direct marketing or market research that you receive from Bright Box (or when you are contacted by electronic means by Bright Box ) will provide a simple means for you to refuse further marketing from Bright Box. For example, in s it may provide you with an unsubscribe link, or an address to which you can send an opt-out request. We will take steps to stop any marketing to which you object or in respect of which you withdraw your consent within a reasonable period, in order to allow sufficient time for the change to be administered. 6.3 In such cases, we will not necessarily remove all your personal data from our database(s) if (for example) retention of your personal data is still required in order to deliver REMOTO or remain aware of your preference not to receive marketing correspondence, which we will note and respect in any event. 6.4 Please note, we are not responsible for any electronic communications or direct marketing sent to you by any third party who you have consented to receive marketing materials

4 from. In such instances, you should refer to the privacy policy of that third party in relation to such matters. 7. What safeguards are in place to protect your personal data? 7.1 Subject to paragraph 7.2 (below), Bright Box takes steps to protect the security of your personal data in accordance with applicable law. Bright Box and any other data processors acting on behalf of Bright Box will be required by Bright Box to implement appropriate technical and organisational measures to protect the personal data they process against any unauthorised access, alteration, transmission, public disclosure, deletion or destruction, as well as damage and accidental loss or deletion of the personal data. 7.2 We cannot guarantee the security of any transmission of personal data over the Internet. Communications over the Internet such as s are not secure unless they have been encrypted. So, while we strive to protect such information, we cannot ensure or warrant the security of any information transmitted to us. Please do not submit personal data through the App or via any Bright Box website unless you accept the inherent security risks and implications of using the Internet. 8. What rights do you have to review, amend and/or delete personal data? 8.1 You have the right to request certain information about the processing of your personal data. These rights vary depending on the country you are based in, but generally include (amongst others) the right to request copies of, access and, in certain circumstances under applicable laws, oppose the processing of your personal data and/or request the deletion of your personal data held by Bright Box and to have certain inaccurate information about you corrected. 8.2 If you wish to exercise any of your rights of access, rectification, cancellation and/or opposition or if you have any questions about this Policy, please contact us using the details set out in Annex If you believe that any information we have about you is incorrect or incomplete, please write to or us as soon as possible. We will take steps to seek to correct or update any information as necessary and in accordance with applicable law and pursuant to our checks on whether that information is in need of correction or update. 8.4 All requests to amend, update, delete, access or to obtain copies of your personal data will be processed in accordance with applicable law. 8.5 Where the processing of your personal data is done with your consent, please note you have the right to withdraw your consent at any time. If you wish to withdraw your consent, please contact us using the details set out in Annex 1 9. Keeping you informed and record retention Bright Box may keep your details on record for as long as is necessary for the purposes for which it may use your personal data, as set out above and as allowed in accordance with applicable law. 10. Changes to this Privacy Policy 10.1 We may change this Policy from time to time by updating this page in order to reflect changes in the law and/or our privacy practices. We will update the date at the top of the Policy accordingly Where required to do so by applicable law, we will provide notice of any changes. However, we encourage you to check this Policy for changes whenever you use the App Subject to any other requirements of applicable law, by using the Website, submitting your personal data to us and/or registering an account, you consent to the use and processing of your personal data as described in this Policy (as amended from time to time). 11. Right to withdraw consent. At any time you are entitled to withdraw consent to provide personal data. To withdraw consent you shall either delete the App, or delete profile through App, or de-activate dongle via car maker office, or erase profile from the App. Upon withfrawing the consent the Company is obliged to erase the data within reasonable period of time but not exceeding one month. 12. Contact us If you have any questions about this Policy, please contact us using the details set out in Annex 1.

5 Annex 1 - Contact Us 1) Contact Us Customers seeking support for Remoto should contact the following: i) their preferred authorised Bright Box office; ii) Bright Box s central customer services (using the telephone number below); or iii) their local Bright Box branch (using the contact us section of their websites) Privacy related requests should be made on the website, using the contact us section of the Bright Box website, submitting an or enquiry outlining clearly what your request is and that it relates to privacy