Privacy Policy — Kobi App

Service operator: Oran Amar, Exempt Dealer (Osek Patur) No. 209232909, Huberman 22, Tel Aviv

The Hebrew version of this Privacy Policy is the legally binding version. This English translation is provided for convenience.

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Oran Amar, Exempt Dealer (Osek Patur) No. 209232909, of Huberman 22, Tel Aviv (hereinafter: the “Company”) develops and operates the “Kobi App” application (hereinafter: the “Application”) — a digital aid that assists driving students and driving instructors during practical driving lessons and in preparing for the practical driving test. The Application does not replace the driving lessons themselves, does not manage them, and is not a platform for preparing for the theory test.

This Privacy Policy (hereinafter: the “Privacy Policy” or the “Policy”) details the types of personal information collected by the Company, the purposes of its collection and processing, how it is used, the terms of its transfer to third parties, the period of its retention, and the ways in which you may exercise your rights as a data subject.

This Privacy Policy constitutes an integral part of the Application’s Terms of Use (hereinafter: the “Terms of Use”). Unless otherwise defined, terms not defined in the Privacy Policy shall have the meaning given to them in the Terms of Use. You declare that you have read this Privacy Policy, understood its contents, and agree to it. If you do not agree to this Privacy Policy, in whole or in part, you may not use the Application.

1. Definitions

In this Privacy Policy, the following terms shall have the meanings set out beside them, unless the context requires otherwise:

• “Personal Information” — any information relating to an identified or identifiable person, including information that, when combined with other information, enables such identification.
• “Processing” — any operation performed on Personal Information, including collection, receipt, storage, alteration, retrieval, use, transfer, deletion, and any similar operation.
• “Data Subject” — the person to whom the Personal Information relates.
• “User” — any person registered for and using the Application, including driving instructors and driving students.
• “Instructor” — a licensed driving instructor registered for and using the Application as an aid during practical driving lessons.
• “Student” — a driving student registered for and using the Application to assist in preparing for the practical driving test.
• “Service Provider” — any external party that processes Personal Information on behalf of the Company for the purpose of providing the service.

2. Information we collect

2.1. Information you provide directly at registration

In the course of registering for and using the Application, you may be asked to provide the Company with details about yourself. You declare that you understand you are not legally required to provide this information to the Company, and that the information is provided of your own will and with your consent. However, failure to provide certain information may limit your ability to use the Application’s features in full.

2.1.1. Information common to all Users

• Full name
• Email address
• Role type (driving instructor / driving student)

2.1.2. Information specific to driving students

• Type of driving license sought (private vehicle, motorcycle, and others)
• Number of lessons completed — optional
• Bureaucratic status related to the licensing process — optional

2.1.3. Information specific to driving instructors

• National ID number
• Mobile phone number
• Name of the driving school at which the instructor operates
• Geographic area of activity
• Details of the vehicle used for instruction — optional

2.2. Information collected via third parties

When you sign in to the Application using Google Sign-In or Sign in with Apple, we may receive basic Personal Information such as name, email address, and a unique identifier, in accordance with the permissions you granted those services.

2.3. Information collected automatically when using the Application

When you use the Application, technical and operational information may be collected automatically, including:

• End-device type, operating system, and version
• Installed Application version
• IP address
• Unique device identifiers
• Usage data, pages and features you used, and duration of use
• Performance and crash data collected via monitoring tools (Sentry)

Please note that any information that is not identified information about you, but is linked to identified information about you, will be treated by us as Personal Information for as long as such a link exists.

2.4. Information collected during driving lessons

During active driving lessons conducted through the Application, and subject to consent given once during registration for the Application (Onboarding), the Application may collect:

• 2.4.1. Audio recordings — activated by the Student at the start of each lesson. The recording is stored on servers and used for AI analysis and feedback on practical driving performance.
• 2.4.2. Video recordings (optional) — subject to a separate explicit consent, video recording may be enabled during the lesson. Video recordings are stored on the User’s device only and are not uploaded to the Company’s servers.
• 2.4.3. Location data (GPS) — collected throughout the lesson to track the driving route, analyze maneuvers, and improve driving instruction. Please note that collection of location data depends on the permissions you set on your device.
• 2.4.4. Lesson metadata — lesson start time, end time, and total lesson duration.

2.5. Learning and progress data

The Application collects and processes data relating to the User’s learning progress, including:

• Readiness metrics for the practical driving test
• Daily goals and experience-point (XP) balances
• Lesson summaries generated by artificial intelligence
• Practice and learning-game data

3. Purposes of collection and processing

Information collected will be used solely in accordance with this Privacy Policy, for the purposes set out below:

1. Operating the Application and managing the User account — including registration, account creation, personal profile management, and connecting Students with Instructors for practical driving lessons.
2. Providing driving-assistance services — analyzing drives, generating professional AI-based feedback to improve practical driving performance, and measuring readiness for the practical test.
3. Managing subscriptions, payments, and billing.
4. Customer service and technical support.
5. Improving and developing the Application.
6. Information security and preventing misuse.
7. Complying with legal and regulatory requirements.
8. Statistical and research use — processing aggregated information for analysis and statistics, without time limitation.
9. Digital marketing — the Application may use third-party marketing tracking tools, including Meta Pixel and TikTok Pixel, to display personalized advertisements. Use of these tools is subject to your explicit consent, which will be requested on a dedicated screen at registration. You may withdraw this consent at any time through the Application settings.

4. Consent to collection of audio, video, and GPS data

4.1. Requirement of consent

Consent to audio recording and collection of GPS data is given by the User only once, on a dedicated and clear consent screen during registration for the Application (Onboarding). The consent specifies the nature of the data collected, its purpose, and how it is processed. The actual audio recording is activated by the Student at the start of each lesson. The Student is responsible for ensuring that the Instructor is informed that recording is being activated, before it begins.

4.2. Withdrawal of consent

The User may withdraw consent to recording at any time through the Application settings. Withdrawal of consent may limit the availability of certain features in the Application.

4.3. Use of recordings

Audio recordings will be used solely for analyzing practical driving lessons and generating AI-based summaries and feedback. No other use will be made of the recordings without additional explicit consent.

5. Transfer of information to third parties

5.1. General principle

Your details and information about you will not be disclosed to third parties without your prior consent, except as permitted under this Privacy Policy.

5.2. Service Providers

The Company uses external Service Providers (data processors) that may process Personal Information on its behalf and at its instruction, and solely for the purpose of providing the service:

The Company undertakes to enter into appropriate agreements with Service Providers, requiring them to keep the information confidential and to act in accordance with legal requirements.

5.3. Additional cases in which information may be transferred to a third party

The Company may also transfer your personal details and information collected about you to third parties in the cases set out below:

1. To a company controlling the Company, a subsidiary, or an affiliated company, for internal corporate purposes;
2. If you breach the Terms of Use or perform acts contrary to law, or attempt to perform such acts;
3. If the Company receives a court order or legal demand instructing it to disclose your details to a third party;
4. If the Company believes that disclosure of the information is necessary to prevent serious harm to your body or property, or to the body or property of another;
5. If the information is statistical, anonymous, and aggregated only, and does not identify you personally;
6. In the event of a sale, merger, acquisition, reorganization, transfer of operations, or dissolution of the Company, provided that a purchasing or successor party undertakes to comply with the provisions of this Privacy Policy.

6. Transfer of information abroad

Information may be transferred to servers in the United States and the European Union. All transfers are performed using encryption (HTTPS/TLS) and in accordance with the requirements of Israeli law.

7. Storage of information and retention period

7.1. Place of storage

All Personal Information is stored on Supabase cloud servers (EU/US). Video recordings are stored on the User’s device only.

7.2. Retention period

Information is retained for as long as the account is active. Upon account deletion, all identified data is deleted: profile, lessons, audio recordings, AI summaries, practice data, subscription, and Tokens. Anonymous and statistical information may be retained for analysis without time limitation.

7.3. Deletion mechanism

Deletion via: Settings → Delete Account. The Company is working to develop additional automatic deletion mechanisms in accordance with legal requirements.

8. Information security measures

The Company employs advanced technical and administrative security measures, including:

1. Encryption in transit and at rest: all data transfers are encrypted using HTTPS/TLS. Stored data is encrypted.
2. Secure authentication: use of strong authentication mechanisms, including OAuth with Google and Apple.
3. Role-based access: access to information is limited on the basis of the User’s role (Role-Based Access Control).
4. Row Level Security (RLS): row-level security in the database, preventing unauthorized access.
5. Secure storage: use of Private Storage and temporary signed links (Signed URLs) for file access.
6. Monitoring and threat detection: ongoing operational monitoring via Sentry, with automatic alerts to the development team.
7. Physical security: cloud-infrastructure security is managed by the cloud providers (Supabase, Google, Apple), in accordance with international standards.

Nevertheless, the Company cannot guarantee that the Application will be absolutely immune to any unauthorized access to information stored by it. Upon discovery of a material security incident, the Company will act in accordance with the law, including reporting to the Privacy Protection Authority and to affected Users, as required.

9. Your rights as a Data Subject

Under the Privacy Protection Law, 5741–1981, you have the following rights:

9.1. Right of access

You are entitled to review the Personal Information stored about you. You may do so directly through the User profile in the Application, and/or by written request to the Company at: team@kobidrive.app. The Company will respond to an access request within 30 days of receipt.

9.2. Right of correction and update

You may update and correct your personal details directly through the “Settings” screen in the Application. Fields that cannot be self-edited (name, email address, national ID number, address, date of birth) may be changed by contacting the Company directly.

9.3. Right of deletion

You may request deletion of your account and identified data at any time, via: Settings → Delete Account. Such deletion will include all identified data as detailed in section 7.2 above. The Company will act to complete the deletion within a reasonable time.

9.4. Right to lodge a complaint

You may at any time contact the Privacy Protection Authority at the Ministry of Justice, at: https://www.gov.il/he/departments/the_privacy_protection_authority, regarding any matter relating to the processing of Personal Information about you.

For any privacy-related inquiry: team@kobidrive.app. The Company will aim to handle inquiries within 30 days of receipt.

10. Use of cookies and digital tracking tools

The Application does not use Cookies. However, the Application uses local storage on the User’s device (Local Storage) to retain an active session and personal settings. In addition, the Application may use third-party marketing tracking tools (Pixels), subject to your explicit consent as detailed in section 3(i) above.

11. Limitations of AI-generated content

The Application uses artificial-intelligence models to analyze practical driving lessons and to generate feedback and summaries. These models may err, and no content, analysis, recommendation, or feedback they produce should be regarded as binding professional advice on driving instruction. The Application is an aid only, and all information produced by the artificial intelligence should be treated with caution. The User is solely responsible for any decision based on the Application’s content.

12. Links to external applications and services

The Application may include links to pages, applications, and websites on the internet that are not operated by the Company, including the Apple and Google app stores. The Company does not control and does not supervise the content of these services, and their responsibility for privacy and information security is governed by their own privacy policies. We encourage you to review the privacy policy of each external service before disclosing any information that enables personal identification.

13. Changes to the Privacy Policy

The Company may from time to time change the provisions of the Privacy Policy. If material changes are made to provisions concerning the scope of information collected, the purposes of processing, or how it is used, advance notice will be published in the Application and/or a direct notice will be sent to the email address registered on the User account. Continued use of the Application after publication of the changes will be deemed your agreement to the updated terms.

14. Contact

For any question, request, clarification, or complaint regarding this Privacy Policy, the processing of Personal Information by the Company, or the exercise of your rights as a Data Subject, please contact us:

Email: team@kobidrive.app