1. Privacy and personal data protection policy

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1.1 The General Data Protection Regulation

The General Data Protection Regulation 2016 (GDPR) is one of the most significant pieces of legislation affecting the way that AURA B.V carries out its information processing activities. Significant fines are applicable if a breach is deemed to have occurred under the GDPR, which is designed to protect the personal data of citizens of the European Union. The same regulation was adopted across all our regions in relation to the Kenya Data Protection Act of 2019 and Protection Of Personal Information Act (South Africa). It is AURA B.V ’s policy to ensure that our compliance with the GDPR and other relevant legislation is clear and demonstrable at all times.

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1.2 Definitions

There are a total of 26 definitions listed within Article 4 – Definitions of the GDPR and it is not appropriate to reproduce them all here. However, the most fundamental definitions with respect to this policy are as follows:

Personal data is defined as: “any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.”

Processing means: “any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.”

Controller means: “the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.”

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1.3 Purpose of Data Processing: Emergency Response

In accordance with legal requirements and to ensure effective emergency response services, we collect and process personal data for emergency situations, primarily aimed at medical and security emergencies. The following types of personal data may be collected:

• Location: GPS coordinates or physical address to pinpoint the individual's location for dispatching emergency responders.
• Name: The individual's full name to identify them and coordinate assistance effectively.
• Vehicle Details (Optional): If the emergency involves a vehicle-related incident, optional details such as vehicle make, model, colour, and licence plate number may be collected to assist emergency responders in identifying the involved vehicle.
• Address: Residential or business address, if different from the current location, to assist responders in reaching the individual or the scene of the emergency.
• Live Location: Real-time location data may be collected through mobile devices or GPS tracking systems to track the individual's movements and provide ongoing assistance.
• Phone Numbers: Contact numbers, including primary and secondary phone numbers, may be collected to establish communication with the individual or their designated emergency contacts.
• Call Recording: All emergency calls are recorded to ensure quality, and may be used as evidence in the event of a claim or court case.

We only share data with emergency responders, providing them with only the information necessary for the scope of the specific emergency. Responders are strictly prohibited from altering the information; their role is solely to provide assistance and upload media as needed for documentation purposes, in accordance with service level agreements (SLAs).

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1.4 Principles relating to processing of personal data

There are several fundamental principles upon which the GDPR is based.

These dictate that personal data shall be:

• Processed lawfully, fairly and in a transparent manner in relation to the data subject (‘lawfulness, fairness and transparency’).
• Accurate and, where necessary, kept up to date (‘accuracy’)
• Kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed (‘storage limitation’).
• Processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures (‘integrity and confidentiality’).

In addition, the controller shall be responsible for, and be able to demonstrate compliance with all of these principles (‘accountability’).

AURA B.V must ensure that it complies with all these principles both in the processing it currently carries out and as part of the introduction of new methods of processing such as new IT systems. The operation of an information security management system (ISMS) that conforms to the ISO/IEC 27001 international standard is a key part of that commitment.

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1.5 Rights of the individual

The data subject also has rights under the GDPR. These consist of:

• The right to be informed
• The right of access
• The right to rectification
• The right to erasure
• The right to restrict processing
• The right to data portability
• The right to object
• Rights in relation to automated decision making and profiling.

Each of these rights must be supported by appropriate procedures within AURA B.V that allow the required action to be taken within the timescales stated in the GDPR.

These timescales are shown in Table 1.

1.6 Consent

Unless it is necessary for a reason allowable in the GDPR, consent must be obtained from a data subject to collect and process their data. In case of children below the age of 16 (Note – this age may be lower in individual EU member states) parental consent must be obtained. Transparent information about our usage of their personal data must be provided to data subjects at the time that consent is obtained and their rights regarding their data explained, such as the right to withdraw consent. This information must be provided in an accessible form, written in clear language and free of charge.

If the personal data are not obtained directly from the data subject, then this information must be provided within a reasonable period after the data are obtained and definitely within one month.

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1.7 Privacy by design

AURA B.V has adopted the principle of privacy by design and will ensure that the definition and planning of all new or significantly changed systems that collect, or process personal data will be subject to due consideration of privacy issues, including the completion of one or more privacy (also known as data protection) impact assessments.

The privacy impact assessment will include:

• Consideration of how personal data will be processed and for what purposes
• Assessment of whether the proposed processing of personal data is both necessary and proportionate to the purpose(s)
• Assessment of the risks to individuals in processing the personal data
• What controls are necessary to address the identified risks and demonstrate compliance with legislation

Use of techniques such as data minimization and pseudonymisation will be considered where applicable and appropriate.

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1.8 Transfer of personal data

Transfers of personal data outside the European Union must be carefully reviewed prior to the transfer taking place to ensure that they fall within the limits imposed by the GDPR. This depends partly on the European Commission’s judgement as to the adequacy of the safeguards for personal data applicable in the receiving country and this may change over time.

It may be necessary for specific contractual terms to be used to cover international transfers. Where possible, these should be based upon standard contractual clauses (SCCs) made available by the relevant authority.

Intra-group international data transfers may be subject to legally binding agreements referred to as Binding Corporate Rules (BCR) which provide enforceable rights for data subjects.

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1.9 Data protection officer

A defined role of Data Protection Officer (DPO) is required under the GDPR if an organisation is a public authority, if it performs large scale monitoring or if it processes particularly sensitive types of data on a large scale. The DPO is required to have an appropriate level of knowledge and can either be an in-house resource or outsourced to an appropriate service provider.

Based on these criteria, AURA B.V requires a Data Protection Officer to be appointed.

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1.10 Breach notification

It is AURA B.V ’s policy to be fair and proportionate when considering the actions to be taken to inform affected parties regarding breaches of personal data. In line with the GDPR, where a breach is known to have occurred which is likely to result in a risk to the rights and freedoms of individuals, the relevant supervisory authority will be informed within 72 hours. This will be managed in accordance with our Information Security Incident Response Procedure which sets out the overall process of handling information security incidents.

Under the GDPR the relevant supervisory authority has the power to impose a range of fines of up to four percent of annual worldwide turnover or twenty million Euros, whichever is the higher, for infringements of the regulations.

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1.11 Addressing compliance to the GDPR

The following actions are undertaken to ensure that AURA B.V complies at all times with the accountability principle of the GDPR:

• The legal basis for processing personal data is clear and unambiguous
• A Data Protection Officer is appointed with specific responsibility for data protection in the organisation
• All staff involved in handling personal data understand their responsibilities for following good data protection practice
• Training in data protection has been provided to all staff
• Rules regarding consent are followed
• Routes are available to data subjects wishing to exercise their rights regarding personal data and such enquiries are handled effectively
• Regular reviews of procedures involving personal data are carried out
• Privacy by design is adopted for all new or changed systems and processes
• The following documentation of processing activities is recorded:
• The following documentation of processing activities is recorded:
• Organisation name and relevant details
• Purposes of the personal data processing
• Categories of individuals and personal data processed
• Categories of personal data recipients
• Agreements and mechanisms for transfers of personal data to non-EU countries including details of controls in place
• Personal data retention schedules
• Relevant technical and organisational controls in place

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These actions will be reviewed on a regular basis as part of the management review process of the information security management system.

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1. Privacy and personal data protection policy

The Information Officer undertakes to review this policy on a yearly basis.

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3. Policy compliance and monitoring

2.1 Compliance Measurement

• The Information Officer is responsible for implementation of this policy and is as such the defined Risk Owner of all risks linked to this procedure in the Risk management and Control Assurance process.
• The Information Officer is the responsible party, as has been defined in Clause 3.
• The Technical Department is as such the defined Control Owner of all aspects related to control assurance related to the valid and effective operation and continued application of the provisions of this policy, within the operational environment.
• The Information Officer is responsible for ensuring that all relevant employees of AURA B.V, as well as relevant external parties are familiar with this document and supporting awareness training materials related to this policy.
• The Technical Department is responsible for ensuring that the implementation of supporting controls ensures the ongoing adherence to the requirements of this policy.
• The Information Officer is responsible for monitoring user compliance and investigating, and reporting breaches of this policy.

2.2 Non-compliance

Relevant employees or contractors of AURA B.V information systems shall comply with this document. Violation of this document and of relevant security requirements will therefore constitute a breach of trust between the employee or contractor, and AURA B.V and may be subject to disciplinary action, up to and including termination of employment or contractual services. Full guidance on specific disciplinary procedures are found in the AURA B.V Code of Conduct and Human Resources Security policy.

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4. Policy validity management

This document is valid as of 27-02-2025.

The owner of this document is the Information Officer, who must check and, if necessary, update the document at least once a year.

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5. Related standards, policies and processes

ISO/IEC 27001: 2022 Information Security Management Systems – A.5 Organisational controls

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6. Regulatory requirements

AURA B.V recognises the importance of complying with all applicable regulatory requirements. Specific reference is made to:

• ISO/IEC 27001:2022(E)
• GDPR 2016/679 (Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC)
• Protection Of Personal Information Act No.4 of 2013
• Kenya Data Protection Act

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7. Reference documents