Data Subject Access Requests

This policy outlines how Driver Technologies Inc. (“DTI”) processes Data Subject Access Requests (“DSARs”) in accordance with applicable privacy laws, including but not limited to the General Data Protection Regulation (“GDPR”) and the California Consumer Privacy Act (“CCPA”).

Scope

This policy applies to all individuals who wish to access, correct, or delete personal data held by DTI, including but not limited to drivers, riders, and other individuals captured by DTI’s dashcam video or audio systems.

Submitting a Request

Requests must be submitted through our DSAR Request Form or by contacting our Privacy Team at privacy@drivertechnologies.com. The request must include:

• Full name and contact information
• Description of the data requested, including any relevant trip ID, date, or location to help identify the footage
• Reason for request (optional)
• Government-issued ID (to verify identity)

Verification of Identity

DTI may request additional documentation to verify the identity of the requestor before processing the request. We reserve the right to deny unverified or incomplete requests.

Response Time

We aim to respond within 30 days of receiving a valid request. In some cases, this period may be extended by an additional 30 days if the request is complex or involves a high volume of data.

Limitations and Exemptions

DTI reserves the right to deny or limit access to data where:

• Disclosing the data would violate the privacy rights of another individual (e.g., other persons visible in video footage)
• The request is manifestly unfounded or excessive
• The data is subject to legal privilege, law enforcement proceedings, or retention obligations

Third-Party Data

Video or audio footage often contains data related to third parties (e.g., license plates, faces, voices). In such cases:

• DTI may redact or anonymize third-party data before disclosing it
• DTI may deny access if redaction is not feasible and third-party rights override the requestor’s access rights

Requests from Authorities

Law enforcement and insurance companies may submit requests through formal channels (e.g., subpoena, court order, claim reference). DTI will comply with valid legal obligations and may provide access without prior notice to individuals.

Guidelines for Evaluating Video Footage Requests

DTI reviews each request for video access with consideration of both the data subject’s rights and the privacy of any third parties captured in the footage (e.g., passengers, pedestrians).

DTI will deny footage access requests under the following conditions:

• The footage contains personally identifiable information (PII) of a third party (e.g., passenger, bystander) and no legal justification exists to override their privacy.
• The footage involves a minor or vulnerable individual without appropriate guardian or legal authorization.
• The requester is not the primary user of the app or vehicle during the recorded timeframe.

DTI may grant limited access to footage if:

• There is clear evidence of a safety or criminal incident, and the footage is required for:
  • Law enforcement investigation
  • Legal proceedings
  • Insurance claims
• Redaction of third-party identities (e.g., faces, license plates) is feasible and does not compromise the footage's integrity.