(Version dated April, 7th 2025)
« SLG Driver » is a mobile application designed for SLG drivers, available for download on Google Play and the Apple Store (hereinafter « SLG Driver’s App » or « App »).
« SLG Driver » is an internal mobile application used by company-employed drivers for managing and executing their assigned transport operations. It facilitates job dispatching, route tracking, and status updates. It allows our drivers to complete specific routes, select pickup points, plan a secure and comfortable itinerary, and benefit from a quick check-out process. Drivers can also check their upcoming trips and easily search for rides.
SLG Driver’s App is owned by S.L.A. S.A., a public limited company under Luxembourg law, a subsidiary of SLG Group, having its registered office at 4 rue Laangwiss, ZAE Robert Steichen, L-4940 Bascharage, and registered with the Luxembourg Trade and Companies Register under number B49878.
SLG Driver’s App is developed, published and, managed under the supervision of IT2GO, a public limited company incorporated under Luxembourg law, having its registered office at 4, rue Belair, L-4514 Differdange and registered with the Luxembourg Trade and Companies Register under number B256656.
By « Drivers » we only mean the drivers employed by S.L.A. S.A. The App is not available to the public or third-party drivers.
References made in this Privacy Policy to either « we » or « us » or « our » refer to S.L.A. S.A, and references to “you,” “your,” or “yours” refer to Drivers using our App services.
This Privacy Policy applies to all personal data that are collected and used by us via SLG Driver’s App.
We determine the ways your personal data are collected and the purposes for which your personal data are used via « SLG Driver’s App » as we are « Data controller » for the purposes arising from Regulation (EU) 2016/679 of the European Parliament and the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (hereinafter « the Regulation » or « GDPR »).
All data protection-related terms used in this Privacy Policy shall have the meanings given to them under the GDPR.
2.1. Data collection
When using the term « personal data » in this Privacy Policy, we mean information that relates to data subjects using SLG Driver’s App services (also referred to as « you » or « your » or « yours ») and allows us to identify you, either directly or in combination with other information that we may hold.
Your personal data may include for example your name, your contact details, your travel itinerary or information on how you use our App or how you interact with us.
We process your personal data only, when it is necessary for the performance of a contract you have concluded with us, or for the fulfilment of a legal obligation to which we are subject. We may process personal data based on our legitimate interest only if this interest is not overridden by your rights.
For more information on the parties with who we may share your personal data, please see Section 7 « Sharing of your personal data » below.
2.2. Categories of data we collect
We may collect and process the following categories of information about you:
We use your personal data for the following purposes:
To ensure efficient routing and navigation for company drivers.
To receive and manage transport assignments.
GPS-based navigation and real-time location sharing.
To record trip start/stop times and status updates.
To view schedules and routes.
With the location data, you use our services and App to improve logistics and operational performance (dispatching coordination)
Recording trip histories is essential for compliance and payroll management.
To comply with legal obligations, including providing data to national authorities if required.
We may need to contact you by email and/or through our App for administrative or operational reasons. We may also send you App notifications for these purposes. To tailor our services and content to your needs and preferences for a more personalized experience.
To improve our service, fulfil administrative purposes including fraud screening, safety, security purposes, maintenance and development.
Please note that we will not share your contact details and other personal data with our partners or other companies for marketing purposes.
We are committed to taking appropriate technical and organisational measures to protect your personal data against unauthorised or unlawful processing and against accidental loss, destruction or damage to personal data.
As described in this Privacy Policy, we may in some instances disclose your personal data to third parties. Where we disclose your personal data to a third party, we require that third party to have appropriate technical and organisational measures in place to protect your personal data; however, in some instances, we may be compelled by law to disclose your personal data to a third party and have limited control over how it is protected by that party.
The information that you provide to us will be securely held in our systems, which are located on our premises or those of an appointed third party, where applicable. We may also allow access to your information by other third parties acting on our behalf for the purposes described in this Privacy Policy or for other purposes you have been informed of. Your personal data may be accessed by and processed outside the European Economic Area (the European Economic Area being the European Union and Iceland, Liechtenstein and Norway, also referred to as the « EEA »). Where your personal data are transferred outside of the EEA, we ensure that appropriate safeguards are in place, such as the European Commission’s Standard contractual clauses or other safeguards of Chapter V under the Regulation are in place.
We will retain your personal data for as long as we need it in order to fulfil our purposes set out in this Privacy Policy or to comply with the law. Further information about the specific retention periods is available upon request.
In the unlikely event there is a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your personal data (such as sending personal data to an incorrect recipient, or loss of availability of personal data), we are committed to taking an informed decision on whether to notify the relevant supervisory authority within 72 hours of becoming aware of such a breach. We commit to informing you without undue delay, in the event the personal data breach is likely to result in a high risk to your rights and freedoms.
In order to improve our services, to provide you with more relevant content and to analyse how visitors use our App, we may use technologies, such as cookies, pixels or tracking software. Please be aware that in most cases we will not be able to identify you from the information we collect using these technologies.
For example, we use software to monitor customer traffic patterns to help us develop the design and layout of the App in order to enhance the experience of the visitors to our App.
We also use cookies in our mobile App. Cookies are small pieces of information stored by your browser on your smartphone’s hard drive. They enable you to navigate on our App and allow us to provide features such as remembering aspects of your last search to make subsequent searches faster. You can refuse and delete cookies if you wish; while certain cookies are necessary for viewing and navigating on our App, most of the features will still be accessible without cookies.
• Category 1: Strictly Necessary Cookies.
These Cookies enable services you have specifically asked for.
These Cookies are essential for enabling you to navigate our App and use its features. Without these Cookies, services you have asked for may not be provided.
We also need to use these categories of Cookie to maintain the App’s effectiveness, ease of use, and to provide you with a seamless experience. As such we have not provided an opportunity for these to be disabled independently, as it will impact the functionality of the App.
• Category 2: Performance Cookies.
These Cookies collect anonymous information on the pages visited.
These Cookies collect information about how you use our App for instance which pages visitors go to most often, and if they get error messages from the App. These Cookies do not collect information that identifies a visitor.
Your personal data may be shared with other companies that we work and provide our services to.
We may also share some of your personal data with, or obtain your personal data from, the following categories of third parties:
We may disclose your personal data when this is required by the law to which the App may be subject.
We may share your personal data with third parties. For instance, your contact details may be directly collected by or disclosed to that third party.
Note: Our partners have their own privacy policies and terms of use over which we do not have control. Whilst S.L.A. S.A. carefully selects these partners, it has no responsibility or liability for their privacy policies, terms of use or the way they process your personal data. Please ensure that you review the relevant privacy policies and terms of use of these partners.
We do not share location data with third parties for advertising or marketing purposes. Location data is used only within the scope of internal company operations.
To summarise, you are entitled to the following rights granted to you by the Regulation, namely:
We shall endeavour to respond to your request promptly and within one month of receipt of the request. Depending on the complexity of the request and the number of requests to handle, we have the ability to extend this response time by two (2) months. You shall be notified of such an extension and of the reasons for the delay within one (1) month of receipt of the request. We reserve the right to reject the request if, on the basis of said request, we are unable to identify you or if the request is deemed excessive or unfounded. You shall be notified of the reasons for refusal within one month of receipt of the request. We may also require the payment of reasonable fees in the case of unfounded or excessive requests, especially if they are repetitive.
You can exercise your rights (e.g. request the deletion of all your personal data from our database) by sending an e-mail to the relevant business entity's e-mail address, which can be found in Section 10 « Contact information », below.
If you are not satisfied with the processing of your personal data, you may submit a complaint by sending a message, email or letter to the relevant business entity found under Section 10 « Contact information ». If you are not satisfied with the handling of your request, you are also entitled to file a complaint with the Commission Nationale pour la Protection des Données (information available on the website www.cnpd.public.lu) or with the competent supervisory authority at your normal place of residence.
We may periodically update this Privacy Policy to reflect changes in our data protection practices or relevant laws.
This Privacy Policy is available on the App Store and the Google Play Store listing and can be accessed anytime within the App settings.
Last update on: 03/04/2025.
Questions, comments and requests regarding this Privacy Policy shall be addressed at the following address gdpr@sales-lentz.lu
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