Privacy Policy

This Privacy Policy describes how Aurea Enterprises sp. z o.o., with its registered office at ul. Plac Bankowy 2, 00-095 Warszawa, entered in the register of entrepreneurs of the National Court Register (KRS) under number 0000510950, NIP: 9591956107, REGON: 260773108, hereinafter “we” or “Multiflota”, processes personal data in connection with the use of the multiflota.pl website, the Multiflota system in a web browser, the Multiflota mobile application and the connection of Multiflota with the ChatGPT and Claude assistants.

In matters concerning personal data protection, you can contact us at privacy@multiflota.pl or in writing at the address of our registered office. We have not appointed a data protection officer.

1. What Multiflota is

Multiflota is a system for managing a company and its vehicle fleet, provided to companies as SaaS. A company using Multiflota, hereinafter “the company”, enters its vehicles and the telematics devices installed in them into the system. The devices send readings to Multiflota, including location, speed, ignition status, odometer readings, fuel level and temperatures. On this basis, Multiflota shows the fleet map, vehicle status, fuel events and fuel reports. In addition, it handles cost invoices, files and document scans, calendars, notifications, an AI assistant and a mobile application.

We set up a company account on the basis of an agreement with the company. User accounts are created by the company, which invites its employees and associates. The mobile application does not create accounts: it connects to an account created in a web browser.

2. Who decides about the data

In Multiflota we act in two roles.

2.1. We are the controller

We are the controller of data processed for the purposes of:

• running the multiflota.pl website and handling contact forms,
• creating and maintaining user accounts, including sign-in and account security,
• concluding and performing agreements with companies and settlements,
• the support chat and handling of requests,
• ensuring the security of the system, including keeping event logs,
• diagnosing errors, including crash reports from the mobile application,
• marketing our own services,
• establishing, pursuing or defending claims.

To this extent, we decide on the purposes and means of data processing.

2.2. We process data on behalf of the company

The controller of data that the company enters into Multiflota or that are transmitted by the devices installed in its vehicles is the company. This applies in particular to data on vehicles and devices, readings from devices, including the location and routes of vehicles, data calculated from readings, invoices, documents, files and scans, calendars, the content of notifications and conversations with the AI assistant.

We process these data as a processor, solely for the purpose of providing the service, in accordance with the agreement, the terms and conditions, the data processing agreement and the company's instructions.

2.3. If you are a driver or an employee of a company

The location and routes of the vehicle you drive, as well as other readings concerning that vehicle, e.g. speed, kilometres driven, driving time or driving style, are your personal data, even when the system shows only the vehicle. We treat the identifier of your driver medium in the same way, if the device in the vehicle reads it.

Your employer or principal decides for what purpose and on what basis the company processes these data, who in the company has access to them and how long it keeps them. Please address questions and requests to them first. We help the company respond to such requests, including establishing from the access log who viewed the vehicle's data and when (section 4.7). If you write to us, we will forward the request to the company or tell you whom to contact.

3. Data we process as the controller

3.1. User account

• first name, middle name and surname,
• email address,
• phone number together with information on its confirmation,
• password, stored only as a cryptographic hash,
• language, time zone and country,
• the companies you belong to and the permissions granted to you in those companies,
• account settings, including notification settings and consent to WhatsApp notifications,
• two-factor authentication data, if you enable it: the encrypted secret of the authenticator app and hashes of backup codes,
• information on acceptance of the terms and conditions and the privacy policy: document type, version and date,
• the date of account activation and of the last sign-in.

We save changes to account data as successive versions, so previous values, e.g. a former email address or phone number, remain in the account history.

3.2. Company data and settlements

• company name, NIP (tax identification number), registered office address, contact email address and type of business,
• contact person details,
• data needed to issue an invoice and payment history,
• information on the selected package or scope of service.

When a company registers through the form on the website, we may retrieve the company's data by its NIP number from public registers: REGON, KRS or CEIDG.

3.3. Contact and support

• data from contact forms: first name and surname, email address, phone, company name, industry, company size, selected package, preferred contact time, message content and information about the page from which the form was sent,
• the content of support chat conversations; after you sign in, we pass your first name, surname and email address to the chat so that you do not need to introduce yourself,
• requests forwarded to us by the ChatGPT or Claude assistant (section 6),
• email correspondence.

Please do not include vehicle location data, driver data or documents in requests, unless this is necessary to resolve the request.

3.4. Technical and security data

• IP address and the type and version of the browser or application,
• sign-in sessions: start date, IP address, browser, device name and client type (browser, mobile application, assistant connection); we store session tokens themselves only as hashes,
• sign-in attempts: the login entered, IP address, browser, result and reason for failure,
• one-time codes sent by email or SMS, stored as hashes, together with the address to which they were sent and the purpose of the code,
• event logs and logs of administrative actions,
• server technical logs; we remove email addresses and tokens contained in page addresses from the logs before saving them.

4. Data the company processes in Multiflota

This section describes data for which the company is the controller (section 2.2).

4.1. Vehicles and devices

• vehicles: name, registration number, VIN, make, model, year of manufacture, vehicle and body type, drive, engine or battery capacity, service dates,
• devices in vehicles: device number, board identifier, IMEI number, SIM card serial number (ICCID), firmware version, time and IP address of the last connection,
• device connection log: addresses, IMEI number and error codes.

4.2. Readings from devices

We save every reading sent by a device in full. A reading may include in particular:

• reading time,
• location, altitude, direction of travel, number of satellites and the country in which the vehicle is located,
• speed, ignition status, odometer readings and engine speed,
• fuel level from probes and sensors,
• temperatures from thermometers,
• supply voltage,
• identifiers of driver and trailer media, if the device reads them,
• working states reported by the tachograph,
• dashboard alarms,
• driving style summaries: distribution of engine speed, speed, acceleration and braking,
• other data sent by the device.

We store readings that cannot be assigned to a vehicle in the same way. We store transmissions from devices that cannot be read for 90 days for diagnostic purposes.

4.3. Fuel and cost invoices

• fuel events calculated from readings: refuelling and fuel losses, with the quantity, time and place of the event,
• fuel reports,
• cost invoices: the seller and its NIP, invoice number and date, amounts and currency, invoice scan, the approving person and the vehicles to which the invoice items relate.

4.4. Files, scans and calendars

• files and document scans together with their name, type, date and title,
• text recognised in scans and images (OCR),
• calendar events: title, description, location, time, organiser and participants,
• if a user connects a Google or Apple calendar: the email address of that account, encrypted access data (Google token or Apple app-specific password) and copies of events from the selected calendars.

4.5. Notifications

The company decides who receives notifications, about which events and through which channel: email, SMS, WhatsApp or the in-app inbox. A notification may contain the vehicle registration number, the amount of fuel, the time and place of the event and, if the recipient sets it up, a link to the place on Google Maps.

• we store the message content until it is sent,
• the delivery history contains the recipient, channel, status and time of delivery, without the message content and without the phone number,
• we store messages in the in-app inbox together with their content,
• we send WhatsApp messages only to a number whose owner has personally consented to this in Multiflota; we store information on the granting and withdrawal of consent and a hash of the number, and a change of phone number invalidates the consent.

4.6. AI assistant

If the company uses the AI assistant, we store conversations: questions, answers, cited sources and the assistant's work steps. The assistant uses fragments of documents (text recognised in files) and calendar events, always within the scope available to the person asking the question. The assistant has no access to vehicle data, device readings or fuel data.

To prepare an answer, we pass the question, earlier messages from the conversation and selected document fragments to the language model provider (section 8). For the same purpose, we prepare document descriptions, summaries and a search index in the background. We do not use the company's data to train AI models.

4.7. Who in the company sees the data

We record everything and show it according to permissions. What a given person sees depends on the permissions granted to them in the company: access to individual functions, e.g. vehicles, fuel or files, and to specific vehicles. Membership of a company alone does not give access to all vehicles.

Multiflota records in the access log who viewed readings, when, in which part of the system (including through the ChatGPT or Claude assistant), for which vehicles and for what period. We also record the generation and viewing of fuel reports.

5. The Multiflota mobile application

The Multiflota mobile application for iPhone shows the fleet map and vehicle status and allows you to scan documents into the company's files.

• Connecting to an account. You connect the phone to your account by scanning a QR code displayed after signing in in a web browser. The phone then sends a pairing code, the device name (usually the phone model) and the application installation identifier. We also record the IP address and information about the application. The phone gets its own session and does not store your password.
• Unlocking. You unlock the application with Face ID or the phone passcode. This is handled by the phone's system: the application only receives the result of the check, and biometric data never leave the phone and never reach us.
• Data on the phone. The application stores information about scans, the upload queue and the selected company in an encrypted database on the phone, and scanned documents in encrypted form until they are sent. The installation identifier is stored in the phone's keychain.
• Document scanner. The scanner uses the iPhone's system document camera. Pages are assembled into a PDF file on the phone and sent to the company's files in Multiflota. When the phone has no network coverage, the upload waits in a queue.
• Map. We retrieve the map from MapTiler servers. MapTiler receives the phone's IP address, information about the application and requests for map tiles of the area being viewed. Vehicle markers are drawn by the application, so MapTiler does not receive vehicle positions.
• Phone location. The application does not use the phone's location and does not ask for access to it. The map shows only the fleet's vehicles.
• Navigation to a vehicle. When you choose directions to a vehicle, the application opens Google Maps with the vehicle's coordinates. From that moment, Google's terms apply.
• Crash reports. When the application encounters an error, it sends a report to the Sentry service, which stores data on servers in Germany. The report contains a description of the error, the phone model, the system version and the application version, without your account data. Before sending, we remove email addresses, tokens, identifiers and file paths from error descriptions. Sentry also counts application launches to measure its stability. We do not record the screen and do not measure performance.
• No tracking. The application does not display advertisements, does not track you across other applications or websites and does not send push notifications.

6. Connection with ChatGPT and Claude

A company may allow its users to connect Multiflota with the ChatGPT (OpenAI) or Claude (Anthropic) assistant. This requires two decisions. The company enables the connection with the given service and confirms that it knows to whom data on the location of its vehicles will be transferred. The company administrator grants a specific person the permission to connect assistants. Disabling the connection by the company immediately ends all connections of that service in the company.

Once connected, the assistant may, at the user's request and within the scope of the user's permissions in Multiflota, retrieve:

• the company name, when checking the connection,
• the last known status of vehicles: the vehicle name and registration number, the last location and country, fuel in the tanks, temperatures, odometer reading and supply voltage, each value with the time of the reading.

These data are transferred to OpenAI or Anthropic and are processed under the terms of that service, within the user's account in that service. Through this connection we do not transfer routes or location history, fuel events, driver identity, driving style, financial data or documents. We record each retrieval of vehicle status in the access log. We do not store the content of conversations with the assistant.

The connection can be ended at any time in the assistant's settings or by asking the assistant to sign out of Multiflota.

If you ask the assistant to pass a comment on to us, the assistant will prepare a message in your own words and will send it only after your confirmation. The message reaches our request system together with the company name, your first name, surname and email address.

7. Purposes and legal bases of processing

To the extent that we are the controller of the data, we process them for the following purposes.

7.1. Creating and maintaining an account

Creating an account, authenticating the user, managing sessions, access and permissions, and enabling the use of Multiflota in a web browser and in the mobile application.

Legal basis: performance of a contract or steps taken prior to entering into a contract, Article 6(1)(b) GDPR.

7.2. Providing the Multiflota service

Maintaining the operation of the system, handling functions selected by the company, sending system messages and notifications, saving user settings.

Legal basis: performance of a contract, Article 6(1)(b) GDPR. We process data for which the company is the controller on the basis of a data processing agreement.

7.3. Contact, support chat and requests

Answering enquiries, handling forms and the chat, conducting correspondence, resolving technical problems and handling complaints.

Legal basis: performance of a contract or our legitimate interest in handling contact and support, Article 6(1)(b) or (f) GDPR.

7.4. Settlements and accounting obligations

Issuing invoices, handling payments, keeping accounts and fulfilling tax obligations.

Legal basis: a legal obligation to which we are subject, Article 6(1)(c) GDPR.

7.5. System security

Protecting accounts against unauthorised access, detecting abuse and bots, keeping event logs, handling incidents and ensuring the accountability of users' actions.

Legal basis: our legitimate interest in ensuring the security of the service, Article 6(1)(f) GDPR.

7.6. Diagnostics and service development

Analysing errors, including crash reports from the mobile application, and improving stability, performance, usability and security.

Legal basis: our legitimate interest in maintaining and improving the product, Article 6(1)(f) GDPR.

7.7. Own marketing

Informing about our services, where permitted by law.

Legal basis: our legitimate interest, Article 6(1)(f) GDPR, and where the law requires consent - consent, Article 6(1)(a) GDPR. Consent may be withdrawn at any time.

7.8. Analytical cookies

Measuring the operation of the website, only with your consent. Details are described in the Cookies Policy.

Legal basis: consent, Article 6(1)(a) GDPR.

7.9. Pursuing and defending claims

Establishing, pursuing or defending claims.

Legal basis: our legitimate interest, Article 6(1)(f) GDPR.

8. Recipients of data

We transfer data to providers that process them on our behalf, to the extent necessary for the operation of a given function:

When you expand the list of countries in the phone number field, the browser downloads flag images from the flagcdn.com service, which then receives the IP address and browser information.

We conclude data processing agreements with providers that process data on our behalf.

In addition, data reach services chosen by the user and are processed there under the terms of those services: Google or Apple after a calendar is connected, OpenAI or Anthropic after the ChatGPT or Claude assistant is connected (section 6), and Google after navigation is opened in Google Maps.

Data may also be disclosed to an accounting office, law firms serving us, and public authorities, courts and other authorised entities, where required by law.

9. Transfers of data outside the European Economic Area

We process most data in the European Economic Area. Data are transferred outside the EEA in connection with the use of the AI assistant (OpenAI), the support chat (Zendesk), bot protection (hCaptcha), WhatsApp notifications (Meta) and maps (MapTiler, Switzerland). Some providers operating in the EEA belong to groups with parent companies in the USA (Twilio, Sentry).

Data are transferred outside the EEA only using the mechanisms provided for in the GDPR: a decision of the European Commission finding an adequate level of protection (including for Switzerland and for US companies participating in the EU-U.S. Data Privacy Framework) or standard contractual clauses.

10. Data retention period

We store data no longer than necessary for the purposes for which we collected them:

• user account data: for the period of use of the service, and then for the period necessary for settlements, handling claims or fulfilling legal obligations,
• settlement and accounting data: for the period required by tax and accounting regulations,
• contact data and requests: for the time needed to handle the matter, and then for the period necessary to demonstrate how it was handled or to defend against claims,
• logs of sign-ins, sessions and security events and the access log: for the term of the agreement with the company,
• device connection log: 90 days,
• transmissions from devices that cannot be read: 90 days,
• crash reports from the mobile application: up to 90 days,
• marketing data: until an objection is raised, consent is withdrawn or the data cease to be useful.

We store data for which the company is the controller in accordance with the agreement and the company's instructions:

• device readings, fuel events and reports, and invoices: for the term of the agreement with the company; the system does not delete them by itself, and the company may order the deletion of the data of a selected device,
• files deleted by a user first go to the trash for 30 days,
• conversations with the AI assistant: up to 365 days from the last activity in the conversation; we delete the conversations of a person who leaves the company earlier,
• Apple calendar synchronisation history: 90 days; events deleted in the Apple calendar: 30 days.

After the agreement ends, we delete or return the company's data in accordance with the data processing agreement.

11. Your rights

To the extent that we are the controller of your data, you have the right to:

• access the data,
• obtain a copy of the data,
• rectify the data,
• erase the data,
• restrict processing,
• data portability,
• object to processing based on our legitimate interest,
• withdraw consent, if processing is based on consent.

Withdrawal of consent does not affect the lawfulness of processing carried out before its withdrawal.

To exercise your rights, write to us at privacy@multiflota.pl. A Multiflota account may be blocked by the company administrator; you may request erasure of your account data at the same address.

We respond without undue delay and no later than one month after receiving the request. In complex cases, this period may be extended in accordance with the GDPR.

If a request concerns data for which the company is the controller, e.g. the location of a vehicle you drive, we will forward it to that company or tell you to contact it directly (section 2.3).

12. Right to lodge a complaint

You have the right to lodge a complaint with the supervisory authority competent for personal data protection. In Poland, this is the President of the Personal Data Protection Office, ul. Stawki 2, 00-193 Warszawa.

We encourage you to contact us before lodging a complaint. Many matters can be resolved faster without formal proceedings.

13. Automated decision-making

We do not make decisions concerning anyone based solely on automated processing that would produce legal effects concerning that person or similarly significantly affect that person.

Multiflota automatically calculates fuel events from readings, such as refuelling and fuel losses, and may send notifications about them. This is information for the company, not decisions: the assessment of events and any decisions concerning drivers and employees are made by people in the company. Answers from the AI assistant are supportive in nature.

14. Data security

We apply technical and organisational measures to protect data against unauthorised access, loss, alteration, disclosure or destruction, in particular:

• encryption of connections,
• encryption of files and scans before they are saved, with a separate key for each file version,
• encryption of stored access data, e.g. for calendars, devices and two-factor authentication, together with recording of every decryption,
• storing passwords and one-time codes only as hashes,
• separation of company data: every query for a company's data is limited to that company, which is verified by automated tests,
• permissions for functions and for specific vehicles, the access log for vehicle data and logs of actions,
• additional verification at sign-in after failed attempts and the option to enable two-factor authentication,
• service access to devices in vehicles only through an encrypted tunnel, on the basis of named and revocable permissions,
• removal of email addresses and tokens from server logs.

No IT system guarantees absolute security, but we design Multiflota to limit the risks associated with data processing.

15. Access of our staff to company data

Members of our team acting as platform administrators have access to the data of all companies in order to maintain, verify and service Multiflota. This applies in particular to vehicle data, device readings, fuel data and user accounts. We record the platform administrator's access to a company's vehicle and fuel data in a log: who viewed whose data and when.

Staff with such access are obliged to maintain confidentiality.

16. Children's data

Multiflota is a service for companies and is not directed at children. We create accounts only for persons designated by the company.

17. Changes to the Privacy Policy

We may change the Privacy Policy, in particular in the event of changes to the system, technological changes, changes of providers, legal changes or changes in the scope of services.

The current version of the Privacy Policy is published on the multiflota.pl website. We may also inform users about significant changes in the application or by email.

18. Contact

In matters concerning privacy and personal data protection, please contact us:

Aurea Enterprises sp. z o.o., ul. Plac Bankowy 2, 00-095 Warszawa. Email: privacy@multiflota.pl.

Language

This document is available in Polish and English. The Polish version is the source text; in case of any discrepancy between the versions, the Polish version prevails. The English version is a translation provided for convenience only.