Effective Date: 10 July 2025

This Privacy Policy governs how Attento Technologies Private Limited (“Attento,” “we,” “us,” or “our”) collects, uses, maintains, and discloses information collected from users (“you” or “your”) of the Attento Platform (or “Platform”), which includes the Attento website (https://www.attento.club), the Attento mobile application (“App”), and any related software or services.

Permissible Age

The Attento Platform is intended only for individuals aged 18 years and above who hold a valid driver’s license and meet the ownership eligibility criteria (vehicle must be owned by self, spouse, or parent).

• If we discover that a user is under 18 years of age, we reserve the right to terminate their account and delete their data.
• Parents or legal guardians should monitor their dependents’ use of the Attento Platform to ensure compliance with this requirement.
• We do not knowingly collect any personal information from users or market to or solicit information from anyone under the Permissible Age. If you believe we might have any information from or about a user under the Permissible Age, please contact us at [email protected]

Information We Collect

A. Information You Provide to Us

When using the Attento Platform, you may provide us with:

• Personal Information: Name, email address, phone number, date of birth and profile details.
• Vehicle Details: Registered vehicle’s make, model, registration number, and ownership details.
• Driver’s License Information: If provided, to verify eligibility.
• Feedback and Support Requests: Information provided when submitting feedback or contacting support.
• Your Preferences: The recorded preferences and settings.
• Searches and Other Activities: Search terms looked up and results selected.
• Content and Transactions: Use of the Platform to participate in responsible driving challenges and results thereof, choice of rewards to be redeemed against Attento Miles.

B. Information Collected Automatically

When you use the Attento Platform, we collect:

• Device Information: Mobile device type, OS version, unique device identifiers, mobile network details, timezone and IP address.
• Driving Behavior Data: Acceleration, braking, speed, cornering, phone usage while driving, and other telematics-based events.
• Location Data: GPS-based tracking (with your consent) for trip analysis and safety assessments.
• Usage Patterns: Data on how you interact with the Attento Platform.

C. Information About Your Friends (Referrals)

If you refer a friend to Attento, we may collect:

• Your Friend’s Contact Details: If you provide a phone number or email to send an invitation.
• Referral Activity Information: We track whether your friend registers and engages with the Attento Platform.

D. Information from Third Parties

We may collect additional information from trusted third-party sources, such as:

• Vehicle Registration and Insurance Data
• Driving License Verification
• Data from Traffic Authorities or Aggregators

How We Use Collected Information

We use the information we collect for the following purposes:

• To provide and operate the Attento Platform
• To personalize your experience
• To improve features and services
• To analyze trends and usage patterns
• To communicate with you about your account
• To send marketing and promotional materials (with your consent)
• To comply with legal and regulatory requirements

Reviewing and Modifying Your Personal Information

Attento is committed to ensuring that the personal information we collect remains accurate, complete, and up to date. As a user of the Attento Platform, you have the right to access, review, and update your personal information stored within your account.

• Reviewing Your Information: You may access most of your personal details, such as your name, contact information, vehicle details, and driving history, directly within the Attento app or website. If you require additional details about the data we hold, you may submit a request by contacting us at [email protected]. We will provide access in accordance with applicable laws and our internal policies.
• Modifying Your Information: If you believe that any personal information we hold about you is incorrect, incomplete, or outdated, you can update it directly within the Attento Platform. For any changes that cannot be made through the platform, you may request corrections by contacting us. We may ask for verification or supporting documentation before making changes to certain types of information.
• Limitations on Access or Corrections: In certain cases, we may be unable to provide access to specific information due to legal, security, or operational reasons. Additionally, we may decline correction requests if we determine that the change would result in incorrect, misleading, or unlawful information being stored in our systems. If we deny a request, we will provide an explanation where legally required.
• Data Retention Considerations: If you request changes to your information after account termination, we may retain certain data as required by legal, regulatory, or business purposes. However, we will take steps to ensure that any retained data is handled in accordance with our Privacy Policy and applicable data protection laws.

Tailored Advertising

We may use collected information to provide personalized advertising based on your driving behavior, location, and interactions with the rewards program. Users may opt out through device settings or by contacting [email protected].

Third-Party Links and Services

The Attento Platform may contain links to third-party websites and services. Attento is not responsible for their privacy policies or data handling practices. Users should review third-party policies before engaging with such services.

How We Protect Your information

We implement commercially reasonable and industry-standard security measures to protect your personal information from unauthorized access, alteration, disclosure, or destruction, including:

• Encryption: Data is encrypted during transmission and storage to protect sensitive information.
• Access Controls: Only authorized personnel can access personal data, with strict authentication mechanisms.
• Regular Security Audits: We conduct routine audits and vulnerability assessments to safeguard user information.

You are responsible for all activity that occurs under your account. You are responsible for maintaining the confidentiality of the access credentials of your account and are fully responsible for all activities that occur under your account. You should not share access to your Attento account, either by way of sharing login credentials or other security information for your Attento account, with anyone. You agree to immediately notify Attento of any unauthorized use of your Attento account or any other breach of security.

Additionally, any instructions or requests received from your authenticated account (e.g., password / passcode / OTP protected login, verified email requests) will be considered as authorized actions. Attento is not responsible for unauthorized access due to user negligence (e.g., sharing login credentials).

Sharing Your Personal Information

We do not sell, trade, or rent your personal information. However, we may share information in the following cases:

• With third-party service providers for data storage, analytics, and customer support. These vendors are contractually obligated to keep your data secure.
• With reward vendors/service providers to facilitate reward redemption.
• With business partners and advertisers, but only in aggregated and anonymized formats that do not identify you personally.
• With legal authorities if required, to comply with legal obligations or protect our rights and the safety of our users.

International Transfers

Your information may be transferred to, stored, and processed in countries other than your own, where data protection laws may differ from those in your country. By using the App and Services, you consent to the transfer of your information to these countries.

Data Retention and Account Termination

A. Data Retention

• We retain your personal data for as long as your account is active or as needed to provide you with the services of the Attento Platform.
• Some driving behavior data and aggregated analytics data may be retained indefinitely for research and platform improvement.
• We may also retain certain data for longer periods when required by law (e.g., compliance with legal obligations or law enforcement requests).

B. Account Termination

You may request to delete your account at any time by contacting us at [email protected]. Upon account deletion:

• Your personally identifiable data will be removed from our active systems.
• Any de-identified or anonymized data may be retained for analytics and research purposes.
• Some data may be retained for legal, regulatory, or security reasons (e.g., fraud prevention, dispute resolution).

Changes to This Privacy Policy

Attento reserves the right to update this Privacy Policy. When we do, we will revise the updated date at the bottom of this page. We encourage users to frequently check this page for any changes to stay informed about how we are helping to protect the personal information we collect. You acknowledge and agree that it is your responsibility to review this Privacy Policy periodically and become aware of modifications. Your continued use of the Attento Platform following the posting of changes to this Privacy Policy will constitute your consent and acceptance of those changes.

Contact

For any questions regarding this Privacy Policy, contact us at [email protected].