1. General Radotrans BVBA (whose registered office is at Driepikkel 6, 9500 Geraardsbergen, Belgium) (“EuroTraveler”,”ET”, “we”, “our” or “us”), acting as data controller, is committed to protect and respect your privacy. This notice (the “Privacy Policy”) is designed to tell you about our practices regarding the collection, use and disclosure of information that you may provide via our mobile applications (the “Aplication“).

This Privacy Policy (together with our Terms and Conditions, any other documents referred to in it ) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

2. What information do we collect from you and for how long? We may collect and process the following data about you:

2.1. Information you give us You may give us information, including information that can identify you (“Personal Data“), when you use our Application, by filling in forms on the Applications (such as the sign-up form), when you enter into any of our competitions, promotions or surveys, when you correspond with us by phone, e-mail or otherwise, and when you report a problem related to the use of our Application.

The information you give us may include:

2.1.1. Mandatory information required to register for the service we provide on our Application or to access other services provided by us, including your name, email address, date of birth and, when you create an account, a password. All these fields are mandatory. EuroTraveler will not be able to provide you with the services offered on our Applications if the required information is not provided or, if applicable, you will not be able to register for a user account on our Application; 2.1.2. A photograph; 2.1.3. A postal address; 2.1.4. Your phone number; 2.1.5. Details on your cars; 2.1.6. Your mini-biography, your gender when you agree to provide that information; 2.1.7. A record of any correspondence between you and EuroTraveler; we may record and/or listen to the phone calls between you and EuroTraveler (for example, with the agents of our Community Relations service). We give you the possibility to object to that processing at the beginning of the call; 2.1.8. A record of any bookings you have made or trip related advertisements you have placed with or through our Application; 2.1.9. Details of accounting or financial transactions including transactions carried out through our Application or otherwise. This may include information such as your payment card or bank account details, details of trips you have booked or offered through our Application; 2.1.10. Details of your visits to our Application and the resources that you access; 2.1.11. Your replies to any surveys or questionnaires, such as your reviews on the trips made through our Application. Such information may be used for analytic & user understanding purposes; 2.1.12. Information we may require from you when you report a problem with our Application or our service, such as the subject of your request for support; 2.1.12. Location information when you have given consent to the collection and processing of these data so that we can respond to your search for trips near to you; 2.1.14. A copy of your Passport, Driving Licence, ID Card and such other similar documents that you have agreed to provide to us. 2.2. Information we collect automatically 2.2.1. If you sign up via social media authentication methods, EuroTraveler will access certain Personal Data (e.g. first name, surname, picture and email) in your social media account pursuant to the applicable terms and conditions of these social media Applications. We may also collect some of your Personal Data when you interact with third party social media features, such as “Like” functions.

2.2.2. With regard to each of your visits to our Application we may collect, in accordance with applicable laws and where required with your consent, information relating to the devices you use and the networks you are connected to when using our services. This may include the following information: your IP address, log-in information, phone type and version, operating system and Application, information about your visit including the URL clickstream to the different pages of our Application, content you viewed or searched for, search terms used, download errors, length of visits to certain pages, the advertising identifier of your device, page interaction and any phone number used to contact us.

2.2.3. We also collect aggregated information regarding your activity on our Application (such as the amount of rides offered, your message response rate, etc.). Such information may be published on your public profile, should you have one.

2.3. Data retention 2.3.1. Except regarding the categories of Personal Data mentioned in clauses 2.3.2 and 2.3.3 below, your Personal Data will be archived after the following retention periods:

5 years after your last use of our Application, if you did not close your account; 30 days after the closing of your account, except if you received a negative rating or report, in which case your data is stored for 2 years following the closing of your account. 2.3.2. The following categories of Personal Data may be stored for different durations:

Financial data (e.g. payments, reimbursements, etc.) is stored for the duration required by applicable tax and accounting laws (for example, the accounting documents are stored for up to 10 years); All user-generated content (e.g. comments, feedback and ratings) is anonymised according to the durations mentioned in section 2.3.1 but remains available on our Application; Log data are stored for up to 12 months from the date of their collection; The phone calls with our Community Relations service are stored for up to 1 month and the analysis documents (such as time and duration of the call) are stored up to 1 year. 2.3.3. In the event that your account is suspended or blocked, we will keep your data for a period of 2 or 10 years depending on the gravity of the breach in order to prevent you from circumventing the rules applying to our Applications.

2.3.4. We may archive some of your Personal Data for a period that will not exceed five (5) years in order to comply with our legal obligations and to manage potential disputes.

3. How do we use the information we collect from you? We will use the information we collect:

PURPOSES

LEGAL BASIS

3.1. To carry out our obligations arising from any contracts entered into between you and us or you and our business partners and to provide you with the information and services that you requested;

This processing is necessary for the performance of our mutual contractual obligations.

3.2. To send you service-related information by email and/or text message and/or any other communication means (e.g. your booking confirmation);

This processing is necessary for the performance of our mutual obligations or carried out with your consent.

3.3. To collect payments from you or to transfer to you the payments we collect on your behalf. This processing is necessary for the performance of our mutual contractual obligations. 3.4. To enable you to personalize your user profile on our Application;

This processing is carried out with your consent. 3.5. To enable you to communicate and interact with other members or with bus transport operators distributed on the Application about our services or about the trip(s) you have/will do and/or to organize such trips;

This processing is necessary for the performance of our mutual contractual obligations or carried out with your consent.

3.6. To give you access to and to enable you to communicate with our Community Relations service; This processing is (i) necessary for the performance of our mutual contractual obligations, (ii) carried out with your consent or (iii) necessary for the establishment, exercise or defense of legal claims.

3.7. To enhance our Community Relation service and train our customers agents through the record of your phone conversations with us; This processing is based on our legitimate interest (to provide you a high quality customer support/to enhance our customer support).

3.8. To ensure compliance with (i) applicable laws, (ii) our Terms and Conditions, and (iii) our Privacy Policy. Certain breaches that we regard as inappropriate may lead to the suspension of your account on our Application. For these purposes, we may use technologies to automatically analyses your use of the Application, including the content of your publications, in order to detect any behavior that may constitute a violation on your part;

This processing is necessary (i) for the performance of our mutual contractual obligations, (ii) is based on your consent or (iii) for the establishment, exercise or defense of legal claims.

3.9. To send you, in accordance with applicable laws and where required, with your consent, marketing materials and information necessary to facilitate the service or the booking process and to make you suggestions and recommendations about goods or services related to our services that may interest you. We also use your data to target you in order to serve our ads on social media Applications or third-party sites. You can learn more about how these features work, and the data that we obtain about you, by visiting the relevant sections of the third party social media Applications or sites.

This processing is based on your consent where required by law or our legitimate interest (i.e. providing you with meaningful advertising).

3.10. To notify you about changes to our services;

This processing is necessary (i) for the performance of our mutual contractual obligations, (ii) for compliance with our legal obligations or (iii) the establishment, exercise or defense of legal claims.

3.11. To verify the information contained in your Passport, Driving License, ID Card and other identity documents that may be collected from you at the time of registration or at any other time during your use of our Application;

This processing is based on (i) your consent, (ii) carried out for the establishment, exercise or defense of legal claims or (iii) for compliance with our legal obligations.

3.12. To administer our Applications and for internal operations, including troubleshooting, data analysis, testing, research, analytic and survey purposes;

This processing is based on our legitimate interest (i.e. ensuring the security of our Application and improving its features).

3.12. To improve our Application to ensure that content is presented in the most effective manner for you and for your device;

This processing is based on our legitimate interest (i.e. providing you with meaningful content).

3.14. To allow you to participate in interactive features of our service, when you choose to do so, such as searching for trips around you based on your location;

This processing is necessary (i) for the performance of our mutual contractual obligations or (ii) based on your consent, where required by law.

3.15. As part of our efforts to keep our Application safe and secure. This processing is based on (i) our legitimate interest (ensuring the security of our Application), (ii) carried out for the establishment, exercise or defense of legal claims or (iii) for compliance with our legal obligations.

3.16. To measure or understand the effectiveness of advertising we serve, and to deliver relevant advertising to our users. This processing is based on (i) our legitimate interest (i.e. measuring and optimizing the efficiency of our advertising campaigns) or (ii) your consent where required by law. 4. Who are the recipients of the Information we collect from you and for which purposes? 4.1. When you use our services, some information about you is shared with the members of our communities or with bus transport operators distributed on our Application, either on your public profile or during the booking process (e.g. we give your telephone number to the members with whom you will share a ride).

4.2. We may receive and send information about you, including your Personal Data, with other EuroTraveler entities and affiliates, for the purposes outlined in this Privacy Policy.

4.3. We are also working closely with third parties which may be the recipients of your Personal Data such as: - social media Applications and which may provide you with connecting services, such as the connection of the information of your EuroTraveler profile, from their social media Applications to our Application; - our business partners who may advertise their services on our Applications and to which you may decide to sign up for. Namely, these services may be insurance services, banking services, rental services, hotels & restaurants, etc. - our business partners who may advertise our services on their websites; - our sub-contractors including in technical, payment, identity verification and delivery services, or analytics providers. 4.4. We only share your Personal Data with any of these third parties mentioned in section 4.3 in the following cases:

4.4.1. Where we resort a third party service provider, for the performance of any contract we enter into with you in order to facilitate or extend our services (e.g. in the framework of the payments made on our Application); 4.4.2. As part of the booking process and in order to provide the requested services, information such as your name, photography, mobile phone number and/or email address, may be displayed on the Application and/or passed on to another member; 4.4.3. As part of our rating system, the reviews you write will be published on the Application. The reviews including your abbreviated name and photography are visible to all visitors of the Application; 4.4.4. We use analytics and search engine providers to assist us in the improvement and optimization of our Applications; 4.4.5. It is explicitly requested by you (e.g. with when using social media authentication methods, subscribe to a service provided by one of our partners, request to participate to an offer or a good deal of one of our partners); 4.4.6. We may distribute parts of our Applications (including the trips you have posted) for display on our business partners’ websites through API or widgets. In these cases, some information from your public profile may be displayed on these websites; 4.4.7. If required to do so by law or in a good faith we believe that it is reasonably necessary to (i) respond to claims asserted against EuroTraveler, (ii) to comply with legal proceedings, (iii) to enforce any agreement with our users such as our Terms and Conditions and our Privacy Policy, (iv) in the event of an emergency involving the danger of public health, death or physical injury to a person (v) in the framework of investigation or (vi) to protect the rights, property or personal safety of EuroTraveler, its members or others ; 4.4.8. In the event that we sell or buy any business or assets, in which case we may disclose your Personal Data to the prospective seller or buyer of such business or assets; 4.4.9. If EuroTraveler or all or part of its assets are acquired by a third party, in which case Personal Data held by it about its members will be one of the transferred assets. 4.5. In accordance with applicable laws and where required with your consent, we may combine information about you, including your Personal Data and cookie information, we send to and receive from our business partners. We may use this information and the combined information for the purposes set out above.

4.6. We draw your attention on the fact that if you decide to share your information, including Personal Data, with us through our business partners’ connecting services, any of our business partners’ privacy policies and/or notices may also be applicable to you, in addition to this Privacy Policy. We do not control the collection and/or the processing of your information eventually made by our business partners on their own Applications.

5. How do we use and moderate your messages? 5.1. We may read the messages you exchange with other members of our community through our Application for fraud prevention, service improvement, customer support purposes, enforcement of the contracts entered into with our members (such as our Terms and Conditions). For example, in order to prevent the circumventing of our online booking system, we may scan and analyse messages sent through our Application to check that they do not include any contact details or references to other websites and, where applicable, messages can be blocked, or totally or partially filtered.

5.2. We never scan or analyse your messages with other members of our community for commercial and advertising purposes. We may use automated methods to carry out the moderation of these messages, but no automated individual decision-making is performed in this regard.

6. Targeted ads and our communications sent by e-mail and/or text messages In accordance with applicable laws and where required with your consent, we may use the information you give us on our Application for electronic direct marketing purposes (e.g. (i) receiving our newsletters, (ii) receiving invitations to our events or other communications that we think may interest you or (ii) serving you with targeted advertising on social media Applications or third parties websites) based on your profile and interests.

For electronic marketing communications: You can withdraw your consent at any time by (i) unticking the relevant box in your member account, (ii) clicking on the unsubscribe link we provide in each communication sent to your attention or (iii) contacting us using the contact details provided in section 12 below.

For targeted ads and content:

on social media (e.g. Facebook): you can object at any time by configuring your settings regarding advertisement directly via your social media account or by contacting us pursuant article 12 below; 7. Is your Information being transferred, how and where? In principle, we store the Personal Data that we hold about you in the European Union (“EU“). However, since for example some of our service providers are based in countries outside of the European Union (“third countries”), we also transfer some of your data to third countries. This may include third countries where the European Commission has not taken the decision that such third country ensures an adequate level of protection. In that case, we ensure that the transfer is performed in accordance with the applicable legislation and that appropriate safeguards have been put in place (especially standard contractual clauses as issued by the European Commission) in order to guarantee a sufficient level of protection of individuals’ private life and fundamental rights.

By sending a request to the Group Data Protection Officer (contact@eurotraveler.app), we can provide you with the details regarding such appropriate safeguards (for example, the standard contractual clauses issued by the European Commission).

8. What are your rights in respect of your personal data? 8.1. You are entitled to receive a copy of your personal data that is in our possession (your right of data access).

8.2 You may request the deletion of personal data or the correction of inaccurate personal data (your right to erasure and rectification). Please note that we may keep certain information concerning you, as required by law, or when we have a legal basis to do so. For instance, if we believe you have committed fraud or violated our Terms and Conditions and we want to prevent you from circumventing the rules applicable to our community.

8.3 You have the right to object at any time (i) to the processing of your personal data for the purpose of direct marketing, or (ii) other processing of your personal data based on our legitimate interest (your right to object to processing).

8.4 You have the right to restrict the processing of your personal data (your right to restriction of processing). Please note that this only applies if (i) you contested the accuracy of your personal data and we are verifying the accuracy of the personal data, (ii) you exercised your right to object and we are still considering, as foreseen by the applicable law, whether the legitimate reasons we are pursuing prevail over yours; or (iii) your personal data has been processed by us in an unlawful way and you request a restriction on their processing rather than erasure; or (iv) we no longer need the personal data for the purposes of processing, but they are still necessary for you to establish, exercise or defend legal claims.

8.5 You have the right to data portability, i.e. the right to receive the Personal Data you have provided us with, in a structured, commonly used and machine-readable format and the right to transmit this data to another controller (your right to data portability).

8.6. You also have the right to make a complaint to the relevant data protection supervisory authority or to seek a remedy through the courts if you believe that your rights have been breached.

8.7. To exercise your rights, please contact the Group Data Protection Officer using the contact details provided in section 12 below.

9. Confidentiality of your password Where you have chosen a password which enables you to access your account on our Application, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

10. Links to other websites and social media Our Application may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy practices and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any Personal Data to these websites.

11. Changes to our Privacy Policy Any changes we may make to our Privacy Policy in the future will be posted on this page. Where appropriate, we will notify you or seek your consent. Please check back frequently to see any updates or changes to our Privacy Policy.

12. Contact & Data Protection Officer If you have any questions about this Privacy Policy or if you have any requests relating to your Personal Data, you can contact us via email to our Data Protection Officer under contact@eurotraveler.app