Annex 5

Privacy Statement

 

Date: 02-09-2025


 

Summary

Your privacy and the protection of your personal data are of great importance to Conneqtech. This summary briefly explains how we handle your data. In addition to this summary, this document contains a detailed description of how Conneqtech processes your data.

Why do we collect your data?
 We collect your data to provide our services and products to you, to assist you with questions, and to inform you about matters that may be of interest to you. In addition, we use your data to improve our services and to comply with legal obligations.

How do we collect data?

What data do we collect?
 
This may vary, but typically includes:

 

What do we do with your data?

 

How long do we retain your data?
 
We only retain your data as long as necessary:

 

How do we protect your data?
 
We take extensive measures to keep your data secure. Only authorized employees have access, and our partners comply with strict European privacy regulations.

What are your rights?
 
You have control over your data. You may:

You can exercise these rights by contacting us at privacy@conneqtech.com. We will always respond within four weeks.

Complaints
 If you are dissatisfied with how we handle your data, please contact us at
privacy@conneqtech.com. You may also file a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens).

For questions, contact us at info@conneqtech.com or visit www.conneqtech.com. We are here to help!


 

Inhoudsopgave

1. Who are we? 4

2. Why and how do we collect information and data from you? 4

3. What do we use your information for? 5

4. The purpose and lawful basis for processing personal data 8

5. How long do we retain your personal information? 9

6. How is your personal data secured and where do we store it? 9

7. Complaints 10

8. Overview Sub processors 11

 


 

1. Who are we?

AXA iN is a service provided by AXA Bike Security, Allegion Netherlands BV using Conneqtech B.V. as its subcontractor (“AXA IN”). AXA iN provides Internet of Things (IoT) services which are able to make autonomous products smart by connecting them to the internet. When you use the services of AXA iN we almost always need to record your personal data. It is our policy and our aim to deal carefully and transparently with the personal data we receive from you.

With this Privacy Statement we tell you how we deal with your personal data, for what purposes and how we process and store your personal data. Therefore, this Privacy Statement applies to all your personal data we process when you visit our website, use our services or when we have contact with you.

 

When you use the services of Conneqtech B.V., it is almost always necessary for us to register your personal data. It is our policy and our objective to handle the personal data we receive from you with the utmost care and transparency. Through this Privacy Statement, we want to inform you how we process your personal data, for what purposes, and in what manner we store and manage such data. This Privacy Statement applies to all personal data we process when you visit our website, use our services, or interact with us in any way.

Conneqtech B.V., leveraging its extensive expertise in the “Internet of Things,” offers smart ICT solutions for businesses, organizations, and consumers that enable (traditional) products and services to be connected to the internet. A core component of Conneqtech’s services is the collection, management, and analysis of data and user information, including telemetry data from Internet of Things (IoT) devices.

For the purposes of this Privacy Statement, “Conneqtech” refers to:
 Conneqtech B.V., a private limited liability company, including its affiliated trade names “
Conneqtor,” “My GPS Tracker,” and “NFNTY.”
 Conneqtech B.V. is registered with the Dutch Chamber of Commerce under number 63567385 and is located at
Hamseweg 22, 3828 AD Hoogland, the Netherlands.

More information about us can be found on our website www.conneqtech.com, or you may contact us via email at info@conneqtech.com or by phone at +31 33 205 3400.

2. Why and how do we collect information and data from you?

Your information and personal data are primarily collected and processed by us in order to provide you with our products and services. We aim to build a long-term relationship with you, so that we can continue to serve you in the future and possibly make offers that may be of interest to you, based on your previous use of our services and your stated preferences.

We collect and process your information and personal data in three ways: directly, through third parties, and automatically.

Directly

We collect and manage data directly from you when you purchase our services and/or products, or when you purchase a product that incorporates our platforms, websites, systems, or apps as an integral component. We also collect data from you when you request information about our products and services, contact us, or otherwise make use of our products and services.

Depending on the service you use, we may process the following personal data:

 

If you are not a customer or user of our services, we do not process personal data about you.

When you use our website, we may process:

 

When you use Conneqtech’s portals (e.g., portal.conneqtech.com, premium.mygpstracker.nl, portal.mygpstracker.nl), we may process:

 

Please note: You are not obligated to provide us with personal data. However, if you choose not to, you may not be able to use our products and services, or only in a limited way.

By means of third parties

We may also collect information about you from third parties. For example, we may collect your name, email address, and other information you share on social media platforms when you interact with us via social media.

Automatically

We automatically collect information—including personal data—when you visit our website or use our services, including our apps. This is done through cookies, web beacons, and other technologies. The automatically collected data may include, but is not limited to: Domain name, Browser type and operating system, Web pages viewed and links clicked, Internet Protocol (IP) address, Time spent on the website and/or using our services, Referring URL or the web page that led you to our website. Where legally permitted, or with your explicit consent, we may combine this automatically collected information with other information we already have about you.

3. What do we use your information for?

We use your information, including your personal data, for the following purposes:

Service delivery

 

Supplier management

 

Customer service

 

Communication

 

Administrative purposes

 

Research and development

 

Legal compliance

 

Protection of ourselves and others

 

Marketing

 

When can we disclose your data?

We may disclose your information, including your personal data, in the following circumstances:


 

Website data

When you use one or more of our websites, certain information is stored automatically, such as:

We use this information for the normal operation and management of our website. We may disclose this information in aggregated form, making it impossible to trace back to any specific individual user.

We are not interested in information that identifies a visitor personally. We are, however, interested in data that shows how our website(s) are used—for example, the number of visitors, the most visited pages, and the busiest times of use.

 

Customer Service and Support

For the handling of support requests, Conneqtech uses external systems, including Freshdesk and AI tools (such as TextCortex).

 

Purpose of processing
 The purpose is to ensure faster and more efficient handling of support requests, allowing us to assist our customers more effectively and carefully.

 

Types of data
 In this context, the following personal data may be processed, provided by you:

 

Cookies and Tracking Mechanisms

We, along with our affiliated labels and subsidiaries, use cookies, tracking pixels, and other tracking technologies to monitor information about your use of our website and the services available through it. We may combine this information with other data we have received about you.

Cookies
 

A cookie is a string of text information that a website transfers to the cookie file of the browser on a computer’s hard drive so that it can recognize the user. A cookie typically contains the domain name it came from, the cookie’s lifetime, and a value (usually a randomly generated unique number). We mainly use cookies for the following purposes:

 

 

You can delete cookies yourself, as they are stored on your device. You can use your browser settings or guidance provided by your browser to do so. You may also choose to block cookies by changing your browser settings, or delete previously stored cookies.

 

Clear GIFs, pixel tags, and other technologies
 Clear GIFs are small images with a unique identifier, similar in function to cookies, invisibly embedded in web pages. We may use clear GIFs (also known as web beacons, web bugs, or pixel tag
s) on our website to track visitor activity, help us manage content, and compile usage statistics. We may also use clear GIFs in HTML emails to measure response rates, determine whether emails have been viewed, and track whether emails have been forwarded.

 

Third-party analytics – measuring and analyzing visitor behavior
 
We use automated tools and applications to evaluate the use of our website and services. These tools help us improve our services, performance, and user experience. They may use cookies and other tracking technologies.

As part of their “Analytics” service, the American company Google places cookies on our websites and apps. We use Google Analytics to gain insights into how visitors use our websites.


 

The information collected in this way is anonymized as much as possible and stored on Google servers in the United States. Your IP address is explicitly not shared. You can read Google’s privacy policy at www.google-analytics.com.

With Google Analytics and Firebase, we collect, among other things:

 

Google may share this information with third parties if legally required or if third parties process the information on behalf of Google. We cannot influence this. We have not permitted Google to use the data collected via our websites for other Google services beyond those agreed between Conneqtech and Google.

If you wish to opt out, you can download and install the Google Analytics Opt-out Browser Add-on for your browser.

 

Analysis for Management Information

Some of your data may be used to generate management information, such as your usage patterns, household composition, and the country and province in which you reside. Such data is always fully anonymized and cannot be traced back to you as an individual.

 

International Transfer of Personal Data

We may use, disclose, process, transfer, or store personal data outside the country where it was collected—for example, in the United States or other countries. These countries may not provide the same level of protection as your home country.

In addition, there may be cases where personal data is transferred to third-party service providers (e.g., in the United States or other countries) to deliver services to Conneqtech, such as payment processing or web hosting.

Conneqtech uses such third-party service providers to process data for supporting services and administrative purposes. Where Conneqtech engages another company for these purposes, we require that party to protect Conneqtech’s personal data and prohibit them from using such data for any other purpose.

 

4. The purpose and lawful basis for processing personal data

 

Necessary for the performance of the agreement we conclude with you

Your personal data are primarily processed when you purchase one of our products or services. We require your personal data for the execution of the agreement between you and Conneqtech. If you do not provide the requested personal data, you will not be able to use our services, or you will only be able to use them in part. We process your personal data for the following purposes:

When processing your personal data, we comply with the requirements set out in the General Data Protection Regulation (GDPR). There is always a valid legal basis for processing your personal data. We make a careful assessment of your interests as an individual and the interests of our organization.

 

Legitimate business interest

We may process—including storing and protecting—your personal data in the context of improving our services. This may include, but is not limited to, marketing activities, surveys, and research.

By doing so, we are able to continuously improve our services, including by means of direct marketing.

We may also process your data during interactions with our company—via our website or directly with one of our employees—enabling us to handle your questions, complaints, or comments quickly and efficiently. This approach also allows us to build and maintain a long-term relationship with you, which we consider important and actively strive to achieve.

 

 

 

Statutory obligation

The processing—and thus also the storage—of certain personal data is required to comply with statutory obligations.

 

Consent

Where we require additional personal data beyond what is necessary for the purposes described above, we will request your explicit consent before processing such data.

 

5. How long do we retain your personal information?

We will not retain your personal data longer than is necessary to achieve the purposes described in this Privacy Statement, unless we have obtained your explicit and documented consent to retain your data longer (for example, to improve our services), or unless we are subject to a statutory obligation to retain your data for a longer period.

 

Financial data

We retain our financial records for 10 years. This means that all data and documents relating to financial transactions between you and Conneqtech are retained for 10 years after you have purchased our products or services.

 

Data from customer contact moments

Chat sessions with our customer service are deleted within 14 days after the interaction, unless the content of the messages is relevant to the service or product you have purchased, or to potential future services or products.

Recorded phone calls and WhatsApp conversations are deleted within three months.

Emails sent by us to you, emails received by us from you, and complaints you submit are retained for a maximum of 10 years.

 

Processing of personal data with your consent

Personal data that we process on the basis of your consent will be retained until you withdraw that consent and inform us of this in writing. If you have not logged in for two years or more, we will automatically anonymize your account information.

 

6. How is your personal data secured and where do we store it?

We take the security of your personal data extremely seriously. We have implemented both technical and organizational security measures to protect your data against loss or unlawful use, such as unauthorized access. These measures are designed in line with the state of the art and take into account implementation costs, to guarantee an appropriate level of security in view of the risks involved and the nature of the data to be protected.

Our policy is that only those Conneqtech employees who actually require access to your personal data to perform their work are granted such access. All Conneqtech employees are bound by confidentiality agreements to further protect your privacy, and each employee has signed an individual privacy statement.

 

Your data are stored within the European Union, with the exception of your name and email address.

For the proper functioning of our services, we engage sub-processors. These sub-processors act solely on behalf of Conneqtech and only once they have provided sufficient guarantees regarding technical and organizational security measures. These safeguards include, but are not limited to: Binding Corporate Rules. Approved Standard Contractual Clauses on data protection, The EU–US Data Privacy Framework

 

Users must protect their username and user ID when using our website and are responsible for any misuse or unauthorized use of our website via their password and user ID. Users are also responsible for maintaining the confidentiality of their passwords. If, as a user, you have reason to believe that your interaction with us is no longer secure (for example, if you believe the security of your account has been compromised), you must immediately contact us at privacy@conneqtech.com or by mail at: Conneqtech B.V. Attn: Privacy Officer, Hamseweg 22, 3828 AD Hoogland, The Netherlands

 

Your rights: access, rectification, restriction or erasure

You have the right to access, rectify, restrict or erase your personal data. You also have the right to withdraw your consent and to object to our processing of your personal data. Where automated decision-making is used, you have the right to request human review of such decisions.

 

You may also choose not to provide us with certain information, although this may be necessary to use our products and services.

 

You have the right to data portability. This means you can request that we send the personal data we hold about you (for example from our systems) to you or to another organization designated by you. To exercise any of these rights, send your request to privacy@conneqtech.com.  

 

To verify that the request is made by you, please include a copy of your identification document with your request and black out your photo, the MRZ (machine-readable zone), passport number, and BSN/Citizen Service Number. We will respond as soon as possible and within four weeks at the latest.

 

You are also entitled to request restriction of processing where:

 

Where processing is restricted, we will only process the data with your consent or for the establishment, exercise, or defense of legal claims.

 

7. Complaints

Conneqtech would like to point out that you have the option to submit a complaint about the way we handle your personal data. You can let us know by sending an email to privacy@conneqtech.com or by sending a letter to:

Conneqtech B.V. Attn: Privacy Officer, Hamseweg 22, 3828 AD Hoogland, The Netherlands

We will make every effort to investigate your complaint as quickly as possible and to remedy it where feasible.

 

You also have the right to file a complaint with the national supervisory authority, the Dutch Data Protection Authority (Autoriteit Persoonsgegevens). You can do so via the following link:
 
https://autoriteitpersoonsgegevens.nl/nl/contact-met-de-autoriteit-persoonsgegevens/tip-ons 

 

 

This Privacy Statement was last reviewed and amended on 2 September 2025.


 
8. Overview Sub processors

 

Category

Service

Entity

Goal

Tools

Country entity

Dataresidency

Website

Collaboration and Productivity

Office 365

Microsoft Corporation

Email, chat, documents and collaboration

Exchange, Teams, SharePoint, OneDrive en Officeapps (Word,Excel,PowerPoint, Outlook,etc.)

USA

EU

https://www.microsoft.com 

Collaboration and Productivity

Slack

Slack Technologies, Inc.

Real-time messaging and collaboration

Slack

USA

EU

https://www.slack.com 

Collaboration and Productivity

Atlassian Cloud

Atlassian Pty Ltd

Issue and project management

Jira, Confluence

Australia

EU

https://www.atlassian.com 

Infrastructure & Hosting

AWS (EMEA SARL)

Amazon Web Services EMEA SARL

Cloud hosting and infrastructure

AWS

Luxembourg

EU

https://aws.amazon.com 

Infrastructure & Hosting

Google Cloud

Google LLC

Cloud hosting and analytics

Firebase, Analytics, Google Cloud

USA

EU

https://cloud.google.com 

Marketing & Communication

Mailchimp

The Rocket Science Group LLC (Intuit)

Email marketing and campaign automation

Mailchimpplatform

USA

USA

https://www.mailchimp.com 

Customerservice

Freshdesk

Freshworks Inc

Support ticketing and customer communication

Freshdesk

USA

EU

https://www.freshworks.com 

Analysing & Tracking

Hotjar

Hotjar Ltd.

Website analytics and behavioral data

Hotjar

Malta

EU

https://www.hotjar.com 

IoT & Telematica

Franson GPS Gate

Franson Technology AB

GPS tracking platform

GPS Gate

Sweden

EU

https://www.gpsgate.com 

IoT & Telematica

Teltonika

UAB Teltonika

Data from digital tachographs

Teltonika cloudplatform

Lithuania

EU

https://www.teltonika.lt 

Recovery

G4S

G4S Secure Monitoring

Recovering assets when reported stolen.

 

Netherlands

EU

www.g4s.nl 

Customerservice

TextCortex

TextCortex

Support ticketing and customer communication

TexCortex

Germany

EU

www.textcortex.com