Privacy Policy

Version of 17 August 2026.

In short. We process your data so you can work as a driver in our fleet: to verify your identity, grant access to a vehicle, calculate your shift, and protect our property. We never sell personal data and never share it with advertisers. All telemetry we collect about your shift is visible to you in the app.

1. Who we are

The data controller is LIMITED LIABILITY COMPANY TWLVCO UKRAINE (ТОВ «Твелвко Україна»), registration code (EDRPOU) 44565438, registered address: 25 Livoberezhna St., Skvyra, Bila Tserkva district, Kyiv region, 09001, Ukraine.

Data protection contact: bve585ukr@gmail.com, phone +380 98 246 24 58.

2. Scope

This Policy covers the DriveTeam mobile application (Android, iOS), the website driveteam.com.ua, and the driver web cabinet — together, the "Service".

3. Data we process

3.1 Data you provide

Full name and date of birth.
Phone number and email address.
Images of your driving licence and passport or national ID card, and the fields extracted from them.
Work experience details you enter in the application form.
Contract signing data: the fact and time of signing, phone number, one-time confirmation code.
Support requests and correspondence with us.

3.2 Data generated while you work

Location. During an active shift the app records your device's location. Outside a shift, background tracking does not run.
Vehicle telemetry for the duration of your shift: state of charge and energy consumption, odometer, speed, state of doors, locks, trunk and windows, gear selector position, warnings and crash events, charging session data.
Vehicle photographs taken when you accept and hand over the vehicle.
Shift start and end times, bookings, vehicle access history and commands sent.
Shift settlements, credits and deductions.

3.3 Technical data

Device identifier and push notification token.
IP address, device model, operating system and app version.
Access records and technical logs.

4. Sources of data

Directly from you; from your device during an active shift; and from the vehicle via the Tesla Fleet API. The vehicle owner connects their Tesla account to the Service and authorises access to that vehicle. We request from Tesla only those categories of data that are necessary for the Service to function.

5. Purposes and legal bases

Purpose	Legal basis
Verifying identity and driving entitlement, admission to work	Performance of a contract; legal obligation
Granting and revoking access to a vehicle	Performance of a contract
Recording shifts, calculating energy consumption and settlements	Performance of a contract
Protecting property: monitoring vehicle condition, detecting damage, responding to accidents and theft	Legitimate interests of the controller
Identifying who was driving at the time of a traffic offence	Legal obligation; legitimate interests
Support, notifications about shifts and payments	Performance of a contract
Accounting and tax records	Legal obligation

Processing is carried out under the Law of Ukraine "On Personal Data Protection". Where the EU General Data Protection Regulation (GDPR) applies, the bases are Articles 6(1)(b), (c) and (f).

6. Transparency towards drivers

This matters to us: you see in the app the same data we see — your routes, energy consumption, shift duration and settlements. You can export them at any time.

7. Who we share data with

We use service providers that process data on our behalf:

Provider	What it processes	Location
Tesla, Inc. and affiliates	Vehicle telemetry and commands	USA / EU
Server hosting provider	The Service database	Germany
Cloudflare R2	Storage of document scans and photographs	EU / global
Google (Gemini) or OpenAI, depending on configuration	Automated text recognition from document scans	USA / EU
Google, Apple	Sign-in, push notifications (FCM, APNs)	USA / EU
Telegram	Phone number verification, operational alerts	EU
TurboSMS	SMS and Viber message delivery	Ukraine
Sentry	Technical error reports	EU

Data may also be disclosed to public authorities, solely on the grounds and within the limits provided by law.

Tesla, Inc. may use information submitted through the Fleet API in accordance with the Tesla Privacy Notice. Where this Policy and the Tesla Privacy Notice conflict in respect of vehicle data processing, the Tesla Privacy Notice prevails.

We do not sell personal data. We do not provide it to advertising networks, data brokers, or any third party for their own purposes.

8. International transfers

Our servers are located in Germany (EU). Some providers listed above may process data in the United States. In those cases we rely on standard contractual clauses or other mechanisms permitted by applicable law.

9. Retention periods

Category	Period
Raw vehicle telemetry	1 year, then aggregated figures only
Detailed GPS tracks	90 days at full resolution, then simplified route geometry
Trips, charging sessions, shift settlements	The retention period prescribed for accounting records
Vehicle access log and command log	Not deleted: required for handling traffic fines and disputes
Document scans	Term of the contract plus the statutory period after its termination
Handover photographs	1 year, or until any related dispute is resolved

10. How we protect data

All data is transmitted over secure channels (TLS); vehicle telemetry uses mutual authentication.
Sensitive fields are encrypted in the database.
Only authorised staff can access driver data, and every access is recorded in an audit log.
Vehicle access keys are held in an isolated environment, separate from public-facing services.
Documents are served only through temporary signed links.

11. Your rights

You have the right to:

know what data we process about you and obtain a copy of it;
have inaccurate data corrected;
request erasure, except for data we are legally required to retain;
restrict or object to processing;
receive your data in a machine-readable format;
withdraw consent where processing is based on consent;
lodge a complaint with the Ukrainian Parliament Commissioner for Human Rights.

To exercise these rights, write to bve585ukr@gmail.com. We respond within 30 days.

12. Automated decision-making

We do not make decisions producing legal effects concerning you based solely on automated processing. The system may flag an event as requiring attention, but decisions about access to work are made by a person.

13. Age of users

The Service is intended solely for adults holding a valid driving licence. We do not knowingly collect data about children.

14. Changes to this Policy

We notify users of material changes in the app and by email at least 14 days before they take effect. The date of the current version is stated at the top of this document.

15. Independence from Tesla

DriveTeam is a service by LLC Twlvco Ukraine: we build a fleet management platform for electric vehicles and operate on it ourselves. DriveTeam is not affiliated with Tesla, Inc. Tesla is a registered trademark of Tesla, Inc.