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الإصدار 1.5 · سارية من 2026-10-05

Schedule 7 — Data Processing Particulars

This is Schedule 7 to the Fleet Partner Agreement ("FPA"). It is the document referred to in clause 15.2 FPA: "In respect of each category of Personal Data processed via the Platform, the controller/processor allocation is as set out in Schedule 7." The list of schedules describes it as "Controller/processor allocation per data category; categories of data subjects and Personal Data; security measures; sub-processors; cross-reference to the DPA." This document supplies exactly that.

It requires no separate acceptance. It becomes binding through the signed Fleet Partner Agreement. There is no tick box for it.

It is the authoritative allocation. The privacy notices (datenschutz, datenschutz-fahrer, datenschutz-partner) summarise the allocation for the respective data subjects. Where a summary and this Schedule differ on an individual category, this Schedule prevails — the notices only describe it.

1. Parties

  • Emaride EU S.à r.l., société à responsabilité limitée under Luxembourg law, represented by its sole manager Ramez Mohamad Alkhalaf, Luxembourg ("Emaride"). Lead supervisory authority: CNPD, Luxembourg (one-stop shop, Art. 56 GDPR).
  • The fleet partner named in the Fleet Partner Agreement ("Fleet Partner"), with the supervisory authority competent for it.

2. Separate Controllers — Art. 26 GDPR Expressly Excluded

Each party determines the purposes and means of its own processing itself and on its own responsibility. There is no joint determination of purposes and means between Emaride and the Fleet Partner.

Art. 26 GDPR (joint controllership) therefore does not apply, and no arrangement under Art. 26(1) is concluded. The parties expressly exclude joint controllership. Accordingly there is no joint allocation of responsibilities to be determined and no essence of an arrangement to be made available to data subjects under Art. 26(2).

Party Own purposes
Emaride Operating the Platform, brokering rides, calculating and displaying the price, checking the approval conditions, invoicing commission and platform fees, safety and fraud prevention, compliance with its own legal obligations
Fleet Partner Performing the transport contract in its own name, engaging and deploying drivers, duty and shift planning, payroll and social security, working-time records, its own tax obligations, its own obligations under transport law

The transfer of data between the parties is therefore a controller-to-controller transfer and not processing on behalf of a controller under Art. 28 GDPR. The consequences are deliberate and are stated here so that neither party assumes the other's position:

  • Each party needs its own legal basis for its own processing and bears responsibility for it.
  • Each party fulfils its own information duty under Arts. 13 and 14 GDPR towards the data subjects it processes.
  • Requests from data subjects are answered by the party that processes the data for its own purpose. The other party forwards the request and names the responsible point of contact.
  • A complaint about one party goes to the supervisory authority competent for that party.
  • Each party is liable under Art. 82 GDPR for its own processing. There is no chain of instructions that shifts that liability.

Where a party does process on the other's instructions, the data processing agreement dpa-fleet-partner applies to that processing alone (clause 15.2 FPA). Clause 3 below states, for each category, whether that is the case. As at this version it is the case for no category of the ordinary Platform operation.

Why this is spelled out: a de facto assumption of joint controllership would create obligations under Art. 26(1) and (2) and a joint responsibility towards data subjects that the processes of neither party support. Naming the allocation is cheaper than litigating it afterwards.

3. Allocation per Data Category

Data category Data subjects Role of Emaride Role of the Fleet Partner Basis for the transfer
Passenger ride data — pickup and drop-off address and coordinates, time, status, ride options, fare passengers controller (brokerage, price, billing, safety) separate controller (performing the transport contract, dispatch, its own records) Art. 6(1)(b) GDPR — necessary to perform the transport contract that the Fleet Partner carries out
Passenger identification for the ride — first name, verification status of the ride code (see clause 4 for what is actually shown) passengers controller separate controller, restricted to carrying out the individual ride Art. 6(1)(b) GDPR
Live location of the driver and the vehicle during an active ride drivers (and, indirectly, passengers through the destination) controller (matching, arrival estimate, disclosure to the passenger) separate controller (fleet overview, dispatch, its obligations as employer or principal) Art. 6(1)(b) and (f) GDPR — performance of the ride and legitimate interests in dispatch and safety
Driver master data and records — name, contact details, driving licence, identity document, police clearance certificate where required (note at the end of this clause), licence validity and status drivers separate controller for the approval check controller as employer or principal (personnel file, engagement, deployment) Art. 6(1)(c) GDPR — clauses 5.1 and 5.2 FPA, transport and licensing law obligations of both parties
Vehicle data and vehicle records — registration, insurance, technical inspection, category, colour, licence plate drivers; the keeper, where a natural person separate controller for the approval check controller as keeper or user of the vehicle Art. 6(1)(c) GDPR — clause 5 FPA, licensing and insurance obligations
Settlement and commission data — fares, commission, platform fees, payouts, chargebacks, invoices contact persons; drivers, where a natural person carries out the ride separate controller (own accounting and tax obligations) separate controller (own accounting, tax, and payroll obligations) Art. 6(1)(c) GDPR — statutory accounting and retention obligations of each party in its own right
Penalties, trainings, ratings, quality measures drivers controller (quality and safety of the Platform, contractual measures) recipient as separate controller, for its own measures as employer or principal Art. 6(1)(f) and (b) GDPR — legitimate interests in safety and quality, and performance of the FPA
Contact person data of the Fleet Partner — account, contract, tax and invoicing details, bank details, link to the payment provider contact persons of the Fleet Partner (owner, manager) controller separate controller for its own personnel and organisational data Art. 6(1)(b) and (c) GDPR — performance of the FPA and statutory obligations
Support tickets and chat content whoever opens or is named in the ticket controller separate controller for the tickets it opens itself Art. 6(1)(b) and (f) GDPR
Log data — change log, login attempts with IP address all Platform users controller no transfer — the Fleet Partner receives no log data not applicable

In none of these categories is one party the processor of the other. Wherever the table says "separate controller", Art. 28 GDPR does not apply and dpa-fleet-partner is not engaged. It is engaged only in the cases listed in clause 1 of that document, none of which forms part of the ordinary operation of the Platform.

Police clearance, medical fitness and company records. Emaride can require a police clearance certificate for every driver as a platform-wide minimum standard; the requirement is switched on by default. While it is switched on, the certificate is uploaded in the Platform like the other driver records, reviewed by Emaride, and a driver is approved only once a reviewed certificate is on file. It is data relating to criminal convictions and offences within the meaning of Art. 10 GDPR and belongs to the category "driver master data and records" above; retention is set out in datenschutz-fahrer. A proof of medical fitness to drive is not requested in the Platform in the EU markets; the obligation under clause 5.1(d) FPA is evidenced outside the Platform, and that record remains with the Fleet Partner under clauses 5.2 and 14.2 FPA. Company-level records under clause 4.3 FPA are uploaded in the Platform; which records, what is stored and who has access is set out in clause 3 of datenschutz-partner. Emaride processes them as a separate controller for the approval check, as with the driver and vehicle records above. The Platform requests no special categories of personal data under Art. 9 GDPR.

4. Data Minimisation Towards the Driver

Before the driver accepts the ride, they see only the passenger's first name, the pickup and drop-off address, and the verification status of the ride — the narrowest set that Art. 5(1)(c) GDPR would allow. The phone number, the rating average and count, the ride count, and the payment-type indicator are disclosed only after the driver has accepted the assignment. This closes the deviation that an earlier version of this Schedule recorded as an open item before go-live (see "Closed", below); datenschutz clause 5 describes the same two-stage state.

What the driver receives about the passenger Actually disclosed Where
First name only — the surname is not disclosed yes driver-facing function ride-customer-info, which reads first_name
Phone number — and it can be dialled and texted directly from the ride screen yes, after acceptance ride-customer-info; the ride screens of the driver app
Average rating and number of ratings of the passenger, aggregated over all their rides yes, after acceptance ride-customer-info
Number of the passenger's completed rides yes, after acceptance ride-customer-info
Payment method used as a category (card via the payment service provider) — no card number, no last four digits yes, after acceptance ride-customer-info
Pickup and drop-off address, with coordinates yes part of the ride record, read in the driver ride flow (bookingsService.getById); the address also appears in a device notification
Verification status of the ride code (status, method, expiry, number of attempts) — never the code itself yes (status) fields of the ride record; the code is held in a separate table that no app role can read
Passenger account identifier (bookings.customer_id) — a technical ID, not a name, email, or other contact detail by itself; links the booking to the passenger's account yes part of the ride record (bookingsService.getById); not rendered on any driver screen, but present in the response the driver's client holds
Ride note (bookings.options.notes, free text up to 500 characters the passenger optionally enters when booking) — its content, and whether one exists at all, is determined solely by the passenger and cannot be itemised further yes part of the ride record (bookingsService.getById); shown to the assigned driver by BookingNoteCard on the request, navigate, and active-ride screens
Email address no —
Card details, IBAN, or other payment data no —
Home address or the passenger's saved addresses no —
The passenger's other rides as individual records no (only a count) —
Individual ratings with free text no —

Timing. ride-customer-info returns a stage of either pre_accept or post_accept. Before the driver has accepted the assignment (stage: pre_accept), the phone number, the rating average and count, the ride count, and the payment-type indicator are not loaded at all — not merely withheld from the response, but never queried, so a driver who declines the ride, or lets it lapse, never received them. Acceptance flips a server-side flag on the booking (bookings.driver_accepted_at, set by the driver-response function); a driver who is later re-dispatched a different ride starts that ride's decision window at pre_accept again. Once the driver has accepted (stage: post_accept), the full set is disclosed, because the driver ride screens need it for the remainder of the ride (contacting the passenger, showing their standing).

Closed. An earlier version of this Schedule recorded the pre-acceptance loading of the phone number, the rating, the trip count, and the payment method as an open item before go-live: none of them are necessary to carry out the individual ride, and their disclosure before the driver had made a decision was a deviation from Art. 5(1)(c) GDPR. It was corrected in the product (commit range ending fix(privacy): Fahrgastdaten erst nach Fahrtannahme, Art. 5 Abs. 1 lit. c (#60), 2026-08-22) rather than talked away in this Schedule, as the prior text already committed to. The Fleet Partner ensures that its drivers use the passenger data only for the individual ride, do not store it beyond the ride, do not pass it on, and do not use it to contact the passenger afterwards (clause 15.3 FPA). Contacting a passenger outside the Platform is also a breach of the anti-circumvention provisions of the Agreement.

5. Categories of Data Subjects and of Personal Data

Data subjects

  • Passengers — consumers and, in the case of business bookings, the authorised employees of corporate clients. A ride booked for business purposes is, in data protection terms, the same processing as one booked privately.
  • Drivers of the Fleet Partner, including an owner who is approved as a driver.
  • Contact persons of the Fleet Partner — owner, management, managers with Platform access.
  • Emaride staff and mandated reviewers, in so far as their actions are recorded in the change log.

Categories of personal data

Category Contains
Identity data first name, surname, date of birth where required for approval, licence and identity document data
Contact data email address, phone number, language, country
Ride data pickup and drop-off address, time, status, ride options, fare, cancellations, no-shows
Location data live position of the driver during an active ride, coordinates of pickup and drop-off
Transaction data fares, commission, platform fees, payouts, chargebacks, payment method as a category, invoices
Record and approval data document type, issue and expiry date, status of the check, vehicle assignment
Communication data tickets, chat content, notifications and emails sent
Log data change log, login attempts with IP address for a short window
Quality data ratings, penalties, trainings, acceptance and cancellation behaviour

No special categories of personal data (Art. 9 GDPR) are requested. Data relating to criminal convictions and offences (Art. 10 GDPR) is processed in the form of the police clearance certificate, where Emaride requires it — see the note at the end of clause 3.

6. Security Measures

The technical and organisational measures under Art. 32 GDPR are set out in dpa-fleet-partner clause 5 and are not repeated here, so that there is a single place to maintain them.

The Fleet Partner implements appropriate security measures of its own for its own processing (clause 15.3 FPA). Because the parties are separate controllers, neither party's measures replace the other's; each answers for its own level of protection.

7. Sub-processors of Emaride

Emaride engages the following processors for its own processing. The table states the purpose and the basis on which data is transferred; drivers and passengers are affected in so far as their data is processed in the service concerned.

Service Purpose Place of processing Basis for the transfer
Supabase Hosting, database, authentication, storage of the record files EU (Frankfurt) Art. 28 GDPR agreement, no third country
Stripe Payment processing and payouts as Merchant of Record, KYB and AML screening US / IE Art. 28 GDPR agreement plus SCC; see below
Google Maps Platform Maps, geocoding, routing US Art. 28 GDPR agreement plus SCC
Mapbox Map rendering (web dashboard) US Art. 28 GDPR agreement plus SCC
Resend Transactional email, ride verification code, record reminders US Art. 28 GDPR agreement plus SCC
Twilio (via Supabase Auth) SMS delivery for the phone-login one-time code — not currently in use US Art. 28 GDPR agreement plus SCC
OpenAI Regulatory digest, AI-assisted ticket triage US Art. 28 GDPR agreement plus SCC
Expo Push notifications to the driver and passenger apps US Art. 28 GDPR agreement plus SCC
Vercel Hosting of the web dashboard and the landing page US Art. 28 GDPR agreement plus SCC
Apple Single sign-on (optional) — not currently in use US Art. 28 GDPR agreement plus SCC
Google Single sign-on (optional) — not currently in use US Art. 28 GDPR agreement plus SCC

Three of the eleven are not currently in operation. Twilio, Apple and Google are marked "not currently in use" above: SMS phone login is switched off at the platform and removed from the app, and Apple and Google single sign-on are not enabled. No personal data reaches these three providers at present. They are retained in the list because they are technically provided for and because clause 6 of the DPA requires 30 days’ advance notice before a sub-processor is put into operation.

For the state of conclusion, Emaride's processor register is authoritative. It records, for each of these eleven providers, the appointment check, the agreement with its date and source, the sub-processor chain, the authorisation, and the objection period. It is deliberately not duplicated here: a second copy would only create a second place to fall out of date. As at the date of this Schedule, none of the eleven agreements is recorded there as concluded; concluding them is a precondition for going live, and the "Basis" column above therefore describes the requirement, not the state achieved.

Changes to this list follow dpa-fleet-partner clause 6: information at least 30 days in advance, right to object within 30 days.

In so far as Stripe carries out the know-your-business, anti-money-laundering, and sanctions screening, it does not act on Emaride's instructions but in order to meet its own regulatory obligations. For that processing it is a separate controller, not a processor of Emaride. Emaride does not hold or manage ride funds itself; cashless card processing is handled exclusively by Stripe as the licensed payment service provider and Merchant of Record.

The Fleet Partner and its drivers are not sub-processors of Emaride, and Emaride's sub-processors are not sub-processors of the Fleet Partner. Both follow from clause 2: the transfer between the parties is not Art. 28 processing, so there is no processing chain into which either could be inserted.

8. Cross-border Transfers

The data is hosted in the EU (Frankfurt). Where a provider named in clause 7 processes outside the EEA, the transfer takes place only under an adequacy decision under Art. 45 GDPR or under appropriate safeguards under Art. 46 GDPR, in particular the EU Standard Contractual Clauses (Implementing Decision (EU) 2021/914), supplemented by an assessment of the legal situation in the recipient country. This mirrors clause 15.4 FPA and dpa-fleet-partner clause 12.

The Fleet Partner transfers driver or passenger data received from the Platform outside the EEA only on the same conditions, and on its own responsibility as a separate controller.

9. Cross-references — the Agreement and This Schedule in Both Directions

So that the chain can be followed from either end:

Reference in the Agreement Points to Resolved by
Clause 15.2 FPA "the controller/processor allocation is as set out in Schedule 7" this document, clauses 2 and 3
Clause 15.2 FPA the data processing agreement "incorporated by reference" dpa-fleet-partner — applicable only in the cases in its clause 1
Clause 15.3 FPA transparency towards drivers, own security measures clause 4 of this document (what the driver actually sees) and datenschutz-fahrer (Emaride's own notice to drivers)
Clause 15.4 FPA international transfers clause 8 of this document, dpa-fleet-partner clause 12
Clause 14.3 FPA audits with minimal disruption dpa-fleet-partner clause 11
Clause 5.1(g) FPA "complies with the Platform Terms of Use and the Driver Terms" nutzungsbedingungen — Part A (general) and Part C (drivers); on data protection, datenschutz-fahrer and clause 4 of this document
Clauses 5.1(c), (d), 4.3 FPA good conduct, medical fitness, company records police clearance certificate and company records in the Platform, medical fitness outside the Platform (note at the end of clause 3)

Conversely, from this Schedule into the Agreement: clause 2 implements clause 15.2 FPA, clause 4 implements clause 15.3 FPA, clause 7 implements Part K of the GDPR Compliance Package, and clause 8 implements clause 15.4 FPA.

Source Our clause Deviation and reason
Clause 15.2 FPA — Schedule 7 named but not delivered all Supplied. The signed Agreement referred to a schedule that did not exist. Without it, clause 15.2 has no content and the allocation of roles is undetermined — which is precisely the question that decides who answers to a data subject.
Schedule list, page 15 FPA — required content clauses 2–8 Adopted item by item: allocation per category, categories of data subjects and of personal data, security measures, sub-processors, cross-reference to the DPA.
Part K — sub-processor register as a template with blanks clause 7 Blanks filled with the eleven providers actually used, with purpose and place of processing. The state of conclusion is not stated here but in Emaride's processor register, and it is stated openly that no agreement is recorded as concluded yet.
Part K — "DPA in place: Yes" in the template clause 7 Not adopted. The template asserts an existing agreement for every row. Asserting one that does not exist would be a false statement in a contractual annex.
Part C, Annex C-1 — data subjects and data categories clause 5 Set out here rather than in the DPA, so that the DPA can refer to a single place.
Art. 26 GDPR clause 2 Expressly excluded, which the package does not do. Reason: the reflex in a brokerage model is to assume joint controllership. The exclusion, together with the reasons and the consequences for rights, complaints, and liability, prevents a de facto joint responsibility that the processes of neither party support.
Clause 15.3 FPA — data minimisation towards drivers clause 4 Stated against the code, not against the intent. The intended minimum (first name, pickup, drop-off, verification status) is what the product discloses before the driver accepts the ride; phone number, rating, trip count, and payment method are disclosed only after acceptance (ride-customer-info, stage: post_accept, closed 2026-08-22, Task 22 #60). The obligation on the Fleet Partner under clause 15.3 (informing drivers of the actual state) applied while this was an open item and is superseded now that the actual state matches the intended minimum before acceptance.
datenschutz clause 5 — what the Driver receives about the passenger clause 4 Consistent. Clause 5 of datenschutz describes the same two-stage state — phone number, rating average and count, ride count, payment-type indicator disclosed only after acceptance. The itemised fields agree in full: the pickup/drop-off row above no longer carries the open-ended "and the remaining fields of the ride record" wording it used to (closed 2026-08-22, Task 19 #62, open item 14 in Emaride's legal open-items list). It now itemises the account identifier and the free-text ride note as well, matching the wording added to datenschutz clause 5 for the same two fields, and none of the itemised fields overlaps with the negative list below in the same table. Fix-round 1 of this Task added the two rows after a review found they were left out of both texts by the narrower wording — the full bookings row the driver's client receives (select('*') via bookingsService.getById) is broader still; that gap is tracked as a new open item, not closed by this wording fix (see LEGAL_OPEN_ITEMS.md).
Part A.1 — contact addresses at @emaride.com clause 1 Changed to @emaride.lu.
Version — Version 1.3, effective from 22 August 2026. Data protection requests and questions about this Schedule: privacy@emaride.lu.