Privacy statement

This is an English translation of our Dutch privacy statement. If the two differ, the Dutch version prevails.

In short

• This website uses no cookies, no analytics and no trackers. Fonts and images come from this website itself.
• If you sign up for the pilot, we only use your details to contact you about the pilot. We don’t store them in a database; they reach us as an email.
• Spoor is in its pilot phase and not yet public. Before real students use the app, we have a privacy expert review the data protection impact assessment (DPIA) and the consent texts.
• Questions, access or deletion: email hallo@spoorrijles.nl.

Who is responsible

De Jouwer is responsible (the controller) for the data that comes in through this website. Dutch Chamber of Commerce (KvK) number 94434808. You can reach us at hallo@spoorrijles.nl.

This website

The website runs on Cloudflare. To deliver the pages and protect the site against abuse, Cloudflare processes technical data about your visit, such as your IP address and your browser. We don’t keep a visitor log ourselves and we don’t measure visitors.

If you choose light or dark in the site’s header, your own browser remembers that choice (in local storage). The choice isn’t sent to us and isn’t a cookie.

The pilot form

You can sign up on the pilot page. We ask for:

Data	Why
Name, email address, phone number (optional)	To call or email you for an intro
Whether you’re a self-employed instructor or a driving school owner, the name of your driving school (optional), where you teach	To see whether the pilot suits you; we’re starting in the Utrecht and Amersfoort region
Your planner, your phone (iPhone or Android), your number of students, whether you use a lesson camera	To prepare the call and your start properly
Your message (optional)	Whatever you want to tell us yourself

Legal basis: your consent, which you give with the tick box under the form. You can withdraw it at any time by emailing us.

What happens: the form goes to a program at Cloudflare that checks the fields and sends them to us as an email through Resend, a service for sending email. There is no database: the email in our inbox is the only copy. To fight spam, Cloudflare briefly counts how often the form is sent from an IP address; we don’t keep that.

Retention: we keep your sign-up for as long as we’re in touch about the pilot, and delete it no later than twelve months after the pilot ends. If you become a customer, we keep what is needed for your account and our records. If you want us to delete everything sooner, email us.

Who else processes your data

• Cloudflare: hosting of the website and the form.
• Resend: sending the email with your sign-up to us.
• Our email provider: that’s where the email with your sign-up is kept.

Cloudflare and Resend are American companies. Our agreements with them as processors include the European Commission’s standard contractual clauses and, where applicable, the EU-US Data Privacy Framework. We don’t sell your data and don’t use it for advertising.

The Spoor app, in short

This statement is about the website. The app itself gets its own privacy statement, and driving schools and instructors get a data processing agreement, before real students take part. This is how the app already works:

• Spoor only records during a lesson the instructor starts. Nothing outside it.
• The student gives separate consent for the route (GPS) and for audio, recorded with who, how and when. Without consent for GPS, Spoor doesn’t record. Consent can be withdrawn at any time.
• The student only sees what the instructor has confirmed. Suggestions from lesson audio only exist with consent for audio.
• How close a student is to the driving test follows fixed, readable rules set by the driving school. There is no model that assesses the student.
• Lesson audio is deleted after 30 days; raw GPS points are thinned out after 30 days.
• Parents only see progress if the student shares it.
• Students can download all their data (with the routes as GPX files) and have it deleted.
• Spoor is built to run in the EU (Amazon Web Services, Frankfurt); speech-to-text goes through Speechmatics in the EU. The public environment isn’t live yet.

More for students and parents is on Your instructor uses Spoor.

Your rights

You have the right to access your data, have it corrected or deleted, object, have its processing restricted and receive your data to take elsewhere. Email hallo@spoorrijles.nl; we reply within a month. If you disagree with how we handle your data, you can file a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens).

Changes

If anything changes, for example when the app goes public, we update this statement. The date at the top shows when that last happened.