PRIVACY POLICY (Website & Mobile App)

• Part A — Website (gazer.com)

  • 1. What personal data is collected on the Website?
    When you create an account or request a catalogue or information about products and services, we may collect your full name, address, phone number, e-mail address and the password of your account. Information requested on the Website may be marked as mandatory or optional. If you do not provide mandatory information, access to some sections may be restricted or we may not be able to answer your request.
  • 2. How is your data used?
    Your data is used to create and manage your account, answer your requests about products and services, send marketing communications according to your preferences and, where you agree, show personalised content and offers on the Website.
    Legal bases: performance of a contract or steps before a contract (account, requests), consent (marketing and personalisation), our legitimate interests (security of the Website) and legal obligations.
  • 3. Data protection
    We use technical and organisational measures to protect your data against unauthorised access, use, modification, deletion, disclosure, unlawful processing, accidental loss and damage, in particular password protection and restriction of access to authorised persons. Absolute security cannot be guaranteed. Please use a strong password, change it regularly and do not share it.
  • 4. Who has access to your data?
    Your personal data is not sold. It may be made available only to:
    • companies of the Gazer group;
    • authorised employees and service providers acting on our behalf (sales support, market research, customer service, account and content management);
    • purchasers or potential purchasers in the event of a sale of the business;
    • authorities where required or permitted by law.
  • 5. Direct marketing
    According to your preferences and applicable law, we may send you offers by post, e-mail or SMS. You can opt out at any time using the unsubscribe link in the message or by writing to info@gazer.com.
  • 6. Deleting your Website account
    Log in, open "My Profile", click "Delete My Account" and confirm. You can also write to info@gazer.com.
  • 7. Third-party websites
    The Website may contain links to websites controlled by third parties. We are not responsible for their practices; please read their privacy policies.
  • 8. Accounts created on other Gazer websites or services
    If you created an account on another Gazer website or service, we may use its data to pre-fill your registration. If you do not want this, contact info@gazer.com.

• Part B — Gazer CAR App and Service

  • 9. What data is processed
    A) Account and authentication
    • phone number (login and one-time codes by SMS);
    • e-mail address, if you use e-mail for one-time codes;
    • password and PIN (stored securely, never in plain text);
    • account and technical identifiers needed to operate the Service.
    B) Vehicle data from the Product installed in the vehicle
    • location: GNSS coordinates, speed, heading, altitude, number of satellites, time stamp; when no GNSS position is available, identifiers of the mobile network cell (MCC, MNC, LAC, Cell ID) are used to estimate the location;
    • trip history and routes;
    • vehicle status: ignition and engine state, engine and cabin/ambient temperature, battery voltage, fuel level (where available), state of doors, hood and trunk, armed/disarmed state;
    • security events: alarm triggers, shock and tilt sensor readings, intrusion and low-voltage alerts, engine start and stop events;
    • remote commands, schedules and settings you set in the App;
    • device and connectivity data: IMEI/serial number, firmware version, SIM card identifiers, signal strength and SIM balance.
    C) Phone location — map display only
    When you use map features (for example "Show on map"), the App may use your phone's precise location to show your position on the map. Your phone's location is processed on the phone and is not sent to our servers.
    D) Push notifications
    Push tokens and delivery data needed to send notifications through Firebase Cloud Messaging.
    E) SMS and e-mail messages
    Phone number or e-mail address, message content (for example a one-time code) and delivery data.
    F) In-app purchases
    For optional subscriptions we receive purchase and transaction identifiers from the App Store or Google Play to confirm the subscription. We do not receive your payment card data.
    G) Gazer E7 dashcam
    Video recordings (and, depending on the model and settings, audio) are stored only on the memory card in the dashcam. They are viewed over a local Wi-Fi connection in the App and are not uploaded to our servers.
  • 10. Purposes and legal bases

    Purpose	Legal basis
    Login, account security, fraud prevention	Contract; legitimate interests
    Showing the vehicle on the map, "find my car", trip history	Contract
    Status, telemetry, security and anti-theft alerts, remote commands	Contract
    Push notifications, SMS and e-mail messages	Contract
    Local weather for climate functions	Contract; legitimate interests
    Confirming subscriptions	Contract
    Stability and security of the Service, technical support	Legitimate interests
    Compliance with legal obligations	Legal obligation

    We do not sell your data and do not use App data for advertising or advertising tracking.
  • 11. Service providers
    We share data only to the extent necessary to operate the Service, with the following providers acting on our behalf:

    Provider	Purpose	Data	Location
    Amazon Web Services	Hosting, databases, storage; SMS delivery (Amazon SNS)	Service data; for SMS: phone number and message	EU (Frankfurt, Germany)
    Twilio	SMS delivery (one-time codes)	Phone number and message	Global
    SendPulse	E-mail delivery (one-time codes)	E-mail address and message	Global
    Google — Firebase Cloud Messaging	Push notifications	Push token and notification text	Global
    Google — Maps Platform	Maps and routes in the App	Map requests	Global
    Google — Geolocation API	Approximate location when no GNSS position is available	Mobile cell identifiers only	Global
    Open-Meteo	Local weather for climate functions	Vehicle coordinates only	EU
    Apple App Store, Google Play	Confirming in-app subscriptions	Purchase and transaction identifiers	Global

    Data may also be disclosed where required by law or by a binding order of a competent authority.
  • 12. Retention
    • Account data: until the account is deleted.
    • Location and trip history: for the lifetime of the account (no automatic time limit), because the Service is designed for long-term history.
    • Event history (alarms and other events): approximately 12 months.
    • Gazer E7 recordings: only on the memory card, until overwritten by loop recording or deleted by you.
    • Limited backups may be kept for a short time after deletion for security, abuse prevention, legal compliance and system integrity, after which they are deleted or anonymised.
  • 13. Permissions
    You can manage App permissions (including location) in your phone settings. If you disable location, map features showing your position may be limited.
  • 14. Deleting your Gazer CAR account
    Deleting the account deletes all associated data, including trips, locations, events and settings.
    • In the App: Settings → Delete account (the path may vary by version).
    • Without access to the App: send an e-mail with the subject "Account Deletion Request" to info@gazer.com or feedback@gazer.com, stating the phone number used for the account. We may ask for additional information to verify that you own the account.
  • 15. Security
    We apply technical and organisational measures, including:
    • data between the Product and our servers is encrypted with an individual AES-128 key of each device;
    • data between the App and our servers is transmitted over HTTPS (TLS);
    • access controls and logging.
    No method of transmission or storage is 100% secure.
  • 16. International processing
    Service data is stored mainly with Amazon Web Services in Frankfurt, Germany (EU). Some providers listed in section 11 may process data outside the UK or the European Economic Area. In such cases we rely on appropriate safeguards required by law, such as adequacy decisions or standard contractual clauses.
  • 17. Children
    The App is not intended for children, and we do not knowingly collect children's data.

• Part C — Information under the EU Data Act

  • This part applies to Gazer connected Products sold in the European Union and to the Gazer CAR Service (Regulation (EU) 2023/2854).
  • 18. Data holder
    Gazer Limited, 17 Hanover Square, London W1S 1BN, United Kingdom, company number 08778057. Contact: info@gazer.com.
  • 19. Product data
    • Gazer S5 and Gazer P8 (4G LTE, GNSS; P8 also Bluetooth) generate the data listed in section 9 B. The data is generated continuously and in near real time while the device is powered and is transmitted to our servers in a binary telematics protocol (EGTS). If there is no mobile connection, it is buffered in the device memory and sent later. Typical mobile data volume for Gazer S5 is approximately 250–350 MB per month.
    • Gazer E7 (dashcam without cloud) stores video files on its memory card only; no data is transmitted to Gazer.
    • Storage and retention: see sections 12 and 16.
  • 20. Use of the data by Gazer
    We use product data only to provide the Service as described in section 10. We do not make product data available to third parties for their own purposes; the service providers in section 11 act on our behalf.
  • 21. Your rights to access, share and delete data
    • Real-time access: location, status, trips and events are available in the App.
    • Copy of the data: you can request a copy of all product data and related service data by e-mail to info@gazer.com, stating the phone number registered in the App. We provide it free of charge in a structured, machine-readable format (JSON or CSV) without undue delay and at the latest within one month.
    • Sharing with a third party: you can ask us at info@gazer.com to make the data available to a third party of your choice, and withdraw that request at any time.
    • Deletion: see section 14. Gazer E7 recordings are deleted in the App or by formatting the memory card.
  • 22. Restrictions
    • Where data relates to an identifiable person other than you (for example another driver), it is provided only where data protection law allows it.
    • Authentication and encryption keys and other data whose disclosure would undermine the anti-theft function are not provided.
    • Device firmware, internal algorithms and the configuration of the security logic are trade secrets of Gazer Limited and are disclosed only with appropriate confidentiality measures.
  • 23. Duration and complaints
    The Service is provided for an indefinite period; the basic Service is free of charge and optional subscriptions can be cancelled in the App Store or Google Play. You can end the Service at any time by deleting your account. You may lodge a complaint with the competent authority under Article 37 of the Data Act in your Member State (in Germany: Bundesnetzagentur).

• Part D — Your rights, changes and contact

  • 24. Your rights
    Under the UK GDPR and the EU GDPR you have the right to access your data, to have it corrected or deleted, to restrict or object to processing, to data portability and to withdraw consent at any time (without affecting earlier processing). To exercise your rights, write to info@gazer.com. You also have the right to lodge a complaint with a data protection supervisory authority — in the UK the Information Commissioner's Office (ico.org.uk), in the EU the authority of your country of residence.
  • 25. Changes to this Policy
    We may update this Policy. The updated version will be published on this page with a new effective date.
  • 26. Contact
    Gazer Limited, 17 Hanover Square, London W1S 1BN, United Kingdom — info@gazer.com, feedback@gazer.com, support@gazer.com