Driving Green Partner App Privacy Policy and Data Usage

Effective Date: 1 January 2026

Last Updated: January 2026

App Name: DG Partner

Operated by: Driving Green

Contact: product@drivinggreen.com

Audience: Authorised B2B partner technicians only

1. Introduction

Driving Green ("we", "us", "our") operates the Driving Green Partner mobile application (the "App"). This Privacy Policy explains how we collect, use, store, and protect information when you use the App as an authorised technician or staff member at a dealership enrolled in the Driving Green programme.

The App is a business-to-business (B2B) tool and is not intended for use by members of the general public. Access requires valid credentials provided by Driving Green to approved partner organisations.

By using the App, you confirm that you have read and understood this Privacy Policy. If you have any questions, please contact us at support@drivinggreen.ie.

2. Data Controller

For the purposes of applicable data protection legislation, including the General Data Protection Regulation (GDPR) and the Data Protection Acts 1988–2018, the data controller is:

Organisation: Driving Green

Website: www.drivinggreen.com

Email: product@drivinggreen.com

3. What Data We Collect

When you use the App to complete a vehicle odometer check, we collect the following categories of data:

3.1  Vehicle and Submission Data

• Vehicle registration number

• Odometer mileage reading (in kilometres)

• Date and time of submission

3.2  Photographic Evidence

• Photo of Tax and Insurance Discs displayed in the windscreen

• Photo of the dashboard odometer reading alongside the Tax Disc

• Photo of the front of the vehicle (including registration plate)

• Photo of the rear of the vehicle (including registration plate)

3.3  Account and Authentication Data

• Your login credentials (username) used to authenticate with the App

• A record of submissions associated with your account

3.4  Technical Data

• Device type and operating system version (collected automatically for diagnostic purposes)

• App version number

• Submission status and error logs

We do not collect your name, home address, personal email address, financial data, or any sensitive personal data as defined under Article 9 of the GDPR.

4. How We Use Your Data

We use the data collected through the App for the following purposes:

• Programme administration: To record and verify electric vehicle mileage as part of the Driving Green programme

• Compliance and audit: To maintain an auditable record of odometer readings and supporting photographic evidence

• Partner obligations: To enable dealership partners to fulfil their obligations under the Driving Green programme agreement

• Quality assurance: To identify and investigate any discrepancies or issues with submissions

• App improvement: To monitor App performance, diagnose technical issues, and improve the user experience

• Legal compliance: To fulfil any legal or regulatory obligations applicable to the Driving Green programme

5. Legal Basis for Processing

We process personal data on the following legal bases under the GDPR:

Contractual necessity: Processing submissions as required under the dealership’s partner agreement with Driving Green

Legitimate interests: Technical data collected for App diagnostics and improvement

Legal obligation: Where processing is required to comply with applicable law or regulation

6. Data Sharing and Disclosure

We do not sell your personal data to third parties.

We may share data in the following limited circumstances:

• Service providers: Technology service providers who host or process data on our behalf (e.g. cloud infrastructure, app platforms), subject to appropriate data processing agreements

• Legal requirements: Where required by law, court order, or regulatory authority

• Business transfers: As part of a business transfer, merger, or acquisition, subject to equivalent privacy protections

• Programme administration: With your dealership’s programme coordinator or Driving Green account manager, in connection with the programme

All third-party service providers are contractually required to handle data in accordance with applicable data protection law and to implement appropriate technical and organisational security measures.

7. Data Retention

We retain submission data (including vehicle registration numbers, mileage records, and photographs) for as long as is necessary to fulfil the purposes set out in this Privacy Policy, and in accordance with the Driving Green programme’s record-keeping requirements.

In practice, this means:

• Submission records and associated photos are retained for a minimum of 6 years from the date of submission to support programme audit and compliance requirements.

• Account credentials are retained for the duration of your dealership’s participation in the Driving Green programme and deleted within 90 days of account deactivation.

• Technical diagnostic data is retained for up to 12 months.

When data is no longer required, it is securely deleted or anonymised.

8. Data Security

We take the security of your data seriously and implement appropriate technical and organisational measures to protect it against unauthorised access, loss, alteration, or disclosure. These measures include:

• Data transmitted between the App and our servers is encrypted in transit using TLS (HTTPS)

• Access to the App and submission data is restricted to authenticated users with valid partner credentials

• Servers and storage systems are hosted within access-controlled environments

• Regular review of security practices and access controls

While we take all reasonable steps to protect your data, no method of electronic transmission or storage is completely secure. In the event of a data breach that poses a risk to your rights and freedoms, we will notify the relevant supervisory authority within 72 hours and, where required, inform affected individuals without undue delay.

9. Your Rights

As a data subject under the GDPR, you have the following rights in relation to your personal data:

• Right of access: The right to request a copy of the personal data we hold about you

• Right to rectification: The right to request correction of inaccurate or incomplete data

• Right to erasure: The right to request deletion of your personal data in certain circumstances

• Right to restriction: The right to request that we restrict the processing of your data in certain circumstances

• Right to object: The right to object to processing based on legitimate interests

• Right to data portability: The right to receive your data in a portable, machine-readable format

To exercise any of these rights, please contact us at product@drivinggreen.com. We will respond to all requests within one calendar month.

You also have the right to lodge a complaint with the Data Protection Commission (DPC), the Irish supervisory authority for data protection matters:

Data Protection Commission

Website:www.dataprotection.ie

Phone: +353 57 868 4800

Address: 21 Fitzwilliam Square South, Dublin 2, D02 RD28

10. Children’s Privacy

The App is intended for use by adult professional technicians and staff at authorised partner dealerships. We do not knowingly collect personal data from individuals under the age of 18. If you believe we have inadvertently collected data from a minor, please contact us immediately at support@drivinggreen.ie.

11. Third-Party Services

The App may connect to the Driving Green platform and, where applicable, Apple platform services (such as the App Store). These services operate under their own privacy policies, which we encourage you to review:

• Apple Privacy Policy: www.apple.com/legal/privacy

We are not responsible for the privacy practices of third-party services.

12. International Data Transfers

The Driving Green programme operates within Ireland and the European Economic Area (EEA). We do not routinely transfer personal data outside the EEA. Where any transfer outside the EEA is necessary (for example, via a third-party service provider), we ensure that appropriate safeguards are in place, such as Standard Contractual Clauses approved by the European Commission.

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, or legal requirements. When we make changes, we will update the “Last Updated” date at the top of this document and, where the changes are material, notify partner dealerships through appropriate channels.

We encourage you to review this Privacy Policy periodically. Continued use of the App after changes have been published constitutes acceptance of the updated policy.

14. Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or the way we handle your personal data, please contact:

Organisation: Driving Green @ Exegy Data Ltd

Email: product@drivinggreen.com

Website: www.drivinggreen.com

We are committed to working with you to resolve any concerns about your privacy in a fair and transparent way.