Privacy Policy for IRAS Bus Assistant

Last Updated: January 2025

1. Introduction

Neoneon Technology ("we," "our," or "us") operates the IRAS Bus Assistant mobile application (the "Service"). This page informs you of our policies regarding the collection, use, and disclosure of personal data when you use our Service.

By using our Service, you agree to the collection and use of information in accordance with this policy.

2. Information Collection and Use

Types of Data Collected:

Personal Information:

  • Name
  • Email address
  • Phone number
  • User account information

Location Data:

  • GPS coordinates (precise location)
  • Location history
  • Movement patterns
  • Geographic location data

Device Information:

  • Device identifiers
  • Operating system information
  • App usage data
  • Performance data

Usage Data:

  • App interactions
  • Feature usage
  • Error logs
  • Analytics data

Purpose of Data Collection:

Location Data is collected for:

  • Real-time bus tracking and monitoring
  • Emergency alert notifications
  • Route optimization and analysis
  • Student safety monitoring
  • Parent communication
  • Compliance with school transportation regulations

Personal Information is collected for:

  • User account creation and management
  • Communication and notifications
  • Customer support
  • Service personalization

Device Information is collected for:

  • App functionality and performance
  • Troubleshooting and support
  • Analytics and improvement
  • Security monitoring

3. Data Processing Legal Basis

For Location Data:

  • Consent: Users explicitly consent to location tracking through prominent disclosure
  • Legitimate Interest: Safety and security of students and transportation services
  • Contract: Necessary for providing transportation services

For Personal Information:

  • Consent: User registration and account management
  • Contract: Service provision
  • Legitimate Interest: Customer support and communication

4. Data Sharing and Disclosure

We do NOT share personal data with third parties except:

  • School administration (for safety and transportation purposes)
  • Emergency services (in case of emergencies)
  • Legal requirements (when required by law)
  • Service providers (under strict data protection agreements)

Data Sharing Details:

  • Location data is shared only with authorized school staff
  • Emergency data may be shared with emergency services
  • Analytics data is anonymized before sharing
  • No data is sold to third parties

5. Data Security

Security Measures:

  • Encryption in transit (TLS/SSL)
  • Encryption at rest (AES-256)
  • Secure server infrastructure
  • Regular security audits
  • Access controls and authentication
  • Data backup and recovery procedures

Data Breach Response:

  • Immediate notification to affected users
  • Notification to relevant authorities within 72 hours
  • Investigation and remediation procedures
  • Regular security training for staff

6. Data Retention

Retention Periods:

  • Location data: 90 days (for safety and compliance)
  • Personal information: Until account deletion
  • Usage data: 12 months
  • Emergency data: 2 years (for legal compliance)

Data Deletion:

  • Automatic deletion after retention period
  • Manual deletion upon user request
  • Secure deletion procedures
  • Verification of deletion completion

7. User Rights

Your Rights Under GDPR/Privacy Laws:

Right to Access:

  • Request copies of your personal data
  • Information about data processing
  • Data portability

Right to Rectification:

  • Correct inaccurate data
  • Update personal information
  • Modify preferences

Right to Erasure:

  • Delete personal data
  • Withdraw consent
  • Request data removal

Right to Restrict Processing:

  • Limit data processing
  • Object to certain uses
  • Suspend data collection

Right to Data Portability:

  • Export your data
  • Transfer to another service
  • Machine-readable format

8. Children's Privacy (COPPA Compliance)

Special Protections for Children:

  • Minimal data collection for children under 13
  • Parental consent required
  • Parental access to child's data
  • Right to delete child's data
  • No behavioral advertising to children

Parental Controls:

  • View child's location data
  • Modify privacy settings
  • Delete child's account
  • Contact us for privacy concerns

9. International Data Transfers

Data Transfer Safeguards:

  • Adequacy decisions where applicable
  • Standard contractual clauses
  • Binding corporate rules
  • User consent for transfers
  • Data localization requirements

10. Cookies and Tracking

Types of Cookies Used:

  • Essential cookies (app functionality)
  • Analytics cookies (usage statistics)
  • Preference cookies (user settings)

Cookie Management:

  • User control over cookies
  • Clear cookie policies
  • Third-party cookie disclosure
  • Cookie consent mechanisms

11. Third-Party Services

Third-Party Integrations:

  • Google Maps (location services)
  • Firebase (analytics and notifications)
  • School management systems

Third-Party Data Sharing:

  • Limited to necessary service provision
  • Data protection agreements
  • User consent for sharing
  • Regular third-party audits

12. Changes to Privacy Policy

Policy Updates:

  • Notification of material changes
  • User consent for significant changes
  • Version control and history
  • Clear communication of updates

13. Contact Information

Privacy Inquiries:

  • Email: [email protected]
  • Phone: +971 042999003
  • Address: IT Plaza, Silicon Oasis, Dubai UAE
  • Privacy Officer: Available through main contact

Data Protection Officer:

  • Contact: [email protected]
  • Response time: Within 30 days
  • Free of charge for reasonable requests

14. Compliance and Certifications

Compliance Standards:

  • GDPR (General Data Protection Regulation)
  • COPPA (Children's Online Privacy Protection Act)
  • Local privacy laws
  • Industry best practices

Certifications:

  • ISO 27001 (Information Security Management)
  • SOC 2 Type II (Security and Availability)
  • Regular compliance audits

15. Additional Provisions

Emergency Situations:

  • Data sharing for safety emergencies
  • Law enforcement cooperation
  • Public safety requirements
  • Legal compliance obligations

Service-Specific Terms:

  • Background location tracking consent
  • Emergency alert data processing
  • School transportation compliance
  • Parent communication protocols

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