This privacy policy informs you about the processing of personal data when using the Ubicheck app provided by ubinam track&act GmbH. The app is used to verify the validity of driver licenses by means of RFID/NFC technology.

1. Data Controller

The controller within the meaning of the GDPR is:

2. Data Protection Officer

Hans-Jürgen Seidel
Telefon +49.450 80 85-0
E-Mail: datenschutz at ubinam.de

(If no Data Protection Officer has been appointed, remove this section.)

3. Data Collected and Transmitted

For each driver license verification, the following data is transmitted to our servers:

• NFC tag identifier (UID): the unique hardware identifier of the RFID chip in the driver license, transmitted in hexadecimal format.
• Timestamp of the verification: date and time of the scan.

No personal content is read from the chip itself – in particular, neither name, date of birth, address, photo, nor driver license classes.

4. Purpose and Legal Basis of Processing

Processing is carried out to perform the driver license check as part of your contractual obligations towards your employer or fleet operator.

The legal bases are:

• Art. 6(1)(b) GDPR (performance of a contract)
• Art. 6(1)(a) GDPR (consent) – your consent is obtained within the app before the first data transmission.

You may withdraw your consent at any time by uninstalling the app. Withdrawal does not affect the lawfulness of processing carried out prior to the withdrawal.

No processing is carried out on the basis of legitimate interests (Art. 6(1)(f) GDPR). No data is collected beyond what is strictly necessary for the driver license verification.

5. Recipients of the Data

The data is transmitted exclusively to servers operated by ubinam track&act GmbH:

• tl.ubinam.eu – Tracking Live production environment
• rh.ubinam.eu – RH production environment
• test.ubinam.eu – Test and staging environment

All servers are operated within the European Union. No data is transferred to third countries.

6. Local Data Storage on the Device

The app stores the following data on your device:

• Diagnostic logs from the last 3 days, used exclusively for support purposes. These logs only leave the device if you actively submit a support ticket.
• Your consent status regarding data transmission.

No personal data is permanently stored on the device.

7. Support Requests

If you submit a support ticket through the app, your message together with the local diagnostic logs described in section 6 are transmitted to our support server. Transmission only takes place upon your explicit action.

8. App Permissions

• Internet – to transmit verification data to the ubinam servers.
• NFC – to read the identifier of the RFID driver license.

9. Analytics and Tracking Tools

The Ubicheck app contains no third-party analytics, tracking or crash reporting tools. In particular, neither Google Analytics, Firebase, Crashlytics nor any comparable service is used.

10. Data Security

We take the following technical and organisational measures to protect your data:

• Encrypted transport: all data transmission between the app and our servers takes place exclusively over an encrypted HTTPS connection (TLS).
• No persistent personal data on the device: the app does not permanently store any personal data on your device. Only your consent status and rotating diagnostic logs (see Section 6) are kept locally.
• No third-party SDKs: the app integrates no analytics, tracking, advertising or crash-reporting libraries from third parties.
• Minimised diagnostic logs: the local logs contain only the NFC tag identifier (UID) and technical HTTP traces; no personal data such as name, date of birth or driver license information is logged. The logs never leave the device unless you actively submit a support ticket (see Section 7).

11. Retention Period

On our servers, drivers are registered together with their NFC tag identifier; we record the most recent verification and the next scheduled verification date. The transmitted verification data is stored for as long as the contractual relationship with the fleet operator (your employer) exists. The data is deleted at the request of the controlling customer, unless statutory retention obligations require longer storage.

12. Your Rights as a Data Subject

You have the following rights regarding your personal data processed by us:

• Right of access (Art. 15 GDPR)
• Right to rectification (Art. 16 GDPR)
• Right to erasure (Art. 17 GDPR)
• Right to restriction of processing (Art. 18 GDPR)
• Right to data portability (Art. 20 GDPR)
• Right to object to processing (Art. 21 GDPR)
• Right to withdraw a given consent (Art. 7(3) GDPR)

To exercise your rights, please contact us using the address provided in section 1.

13. Right to Lodge a Complaint with a Supervisory Authority

You have the right to lodge a complaint with a data protection supervisory authority regarding our processing of personal data. The competent authority is the data protection supervisory authority of the federal state in which ubinam track&act GmbH has its registered office.

14. Changes to This Privacy Policy

We reserve the right to amend this privacy policy in order to ensure that it always complies with current legal requirements or to reflect changes to our services. The version applicable at the time of your next visit will apply.