PRIVACY POLICY

SQUARELABS LIMITED – Website, Fleet Platform and Mobile Application

Last updated: 13 November 2026

1. Introduction

SQUARELABS LIMITED ("SquareLabs", "we", "us" or "our") respects your privacy and is committed to protecting personal information.

We provide technology solutions to businesses, including vehicle tracking, fleet management, asset tracking and associated monitoring services.

This Privacy Policy explains how we collect, use, store and protect information when you:

Visit our website at https://fleet.squarelabs.uk.

Access or use our Fleet management platform.

Use our associated mobile application.

Enter into a business relationship with SquareLabs.

Contact us in connection with our products or services.

Our services are primarily provided to business customers (B2B).

We aim to collect and process only the information necessary to provide our services and operate our business.

2. Who we are

For the purposes of applicable data protection legislation, the organisation responsible for the personal information described in this policy is:

Registered company name: SQUARELABS LIMITED Trading name: SquareLabs Company registration number: 09118329 Registered office: 6 The Beech Tree, Elmhurst Business Park, Lichfield, Staffordshire, England, WS13 8EX Email: [email protected] Telephone: +44 (0)3300 88 2708 Website: https://fleet.squarelabs.uk

Where we process information on behalf of a business customer, we may act as a data processor, with that customer acting as the data controller.

3. Information we collect

We operate our services with data minimisation in mind.

We do not operate a driver profiling system and do not require driver names, personal contact details, photographs, vehicle inspection reports or uploaded documents as part of the Fleet platform described in this policy.

The information we process may include the following:

3.1 Account information

When a business customer registers for or uses our platform, we may collect:

Email addresses associated with user accounts.

Account login and authentication information.

Information necessary to administer and maintain the account.

We do not intentionally collect personal profiles or personal contact information for individual drivers through the Fleet platform.

3.2 Vehicle and IoT device information

Our vehicle tracking and IoT solutions receive information from connected tracking devices and equipment.

This information may include:

GPS coordinates and vehicle locations.

Location timestamps.

Device identifiers.

Vehicle or asset identifiers.

Device status and connectivity information.

Technical information transmitted by connected tracking equipment.

The devices themselves are hardware and are not people. However, depending on the circumstances, location information associated with a vehicle could potentially relate to an identifiable individual.

We therefore handle this information appropriately and do not assume that all vehicle location information is automatically outside the scope of data protection legislation.

3.3 Website and technical information

When you access our website or platform, certain technical information may be collected automatically, including:

IP addresses.

Browser and device information.

Website usage information.

Security and diagnostic logs.

Information collected through cookies or similar technologies, where applicable.

The information collected will depend on the services and technologies in use.

4. How we use information

We use information for the following purposes:

Creating and administering business accounts.

Providing access to our Fleet management platform.

Providing vehicle and asset tracking services.

Displaying vehicle locations and associated tracking information.

Maintaining and supporting connected IoT devices.

Administering subscriptions and payments.

Maintaining platform security and reliability.

Diagnosing technical issues and improving our services.

Responding to customer enquiries and support requests.

Meeting applicable legal and regulatory obligations.

We do not sell personal information to third parties.

We do not use vehicle tracking information for advertising purposes.

5. Legal basis for processing

Where UK GDPR applies, we rely on the appropriate lawful basis for each processing activity.

These may include:

Contractual necessity: Processing account information and providing services required under our agreements with business customers.

Legitimate interests: Maintaining platform security, preventing misuse, supporting our services and improving operational reliability, where these interests do not override the rights and freedoms of individuals.

Legal obligation: Processing information where required to comply with applicable laws and regulations.

Where we process vehicle tracking information on behalf of a business customer, that customer is generally responsible for determining the purposes and lawful basis for the processing. We process that information in accordance with our contractual instructions.

6. Sharing information with third parties

We use selected third-party providers to operate and support our services.

These include:

6.1 Amazon Web Services (AWS)

We use Amazon Web Services (AWS) for cloud hosting and infrastructure.

Our platform infrastructure is hosted in the AWS Ireland region (EU-West-1).

Information processed through our platform may be stored and processed using this infrastructure.

6.2 GoCardless

We use GoCardless as our Direct Debit payment processing provider.

Customers are responsible for setting up and authorising their own Direct Debit mandates directly through GoCardless. Customers retain control of their Direct Debit arrangements, including the management of their mandates through the GoCardless service.

GoCardless handles the relevant payment and banking information required to establish and process Direct Debit payments.

SquareLabs does not intend to store customers' full bank account details within the Fleet platform. We may receive payment-related information, such as payment status or transaction references, where necessary to administer customer subscriptions and reconcile payments.

GoCardless operates its own privacy and data protection arrangements. Further information can be found at https://gocardless.com/privacy/.

6.3 Google Analytics

We use Google Analytics to collect anonymous website traffic and usage statistics to help us understand how visitors interact with our website and improve its performance and usability.

This may include aggregated information about website visits, pages viewed, browser types, devices and general visitor behaviour.

We do not use Google Analytics for advertising, remarketing or targeted advertising purposes.

We do not use Google Analytics to monitor individual vehicle movements or track vehicle GPS information.

We do not sell personal information to Google or other third parties.

We may also disclose information where required by law, to protect our legal rights or to support the security and operation of our services.

7. International data transfers

Our platform infrastructure is hosted in Ireland using AWS EU-West-1.

Ireland is within the European Economic Area (EEA).

Where personal information is transferred outside the United Kingdom or European Economic Area, we will ensure that appropriate safeguards are in place in accordance with applicable data protection legislation.

These safeguards may include adequacy regulations, the UK International Data Transfer Agreement, the UK Addendum to the EU Standard Contractual Clauses or other legally recognised transfer mechanisms, where applicable.

8. Data storage and security

We take reasonable technical and organisational measures to protect information processed through our services.

These measures are designed to protect against:

Unauthorised access.

Accidental loss or destruction.

Unauthorised disclosure.

Unauthorised alteration.

Misuse of information.

Our services are hosted using AWS cloud infrastructure in Ireland (EU-West-1).

Access to platform accounts and associated information is restricted to authorised users and personnel where appropriate.

Although we take reasonable steps to protect information, no internet-based service or electronic storage system can be guaranteed to be completely secure.

9. Data retention

We retain information only for as long as reasonably necessary for the purposes for which it was collected or processed.

Vehicle GPS and tracking data: Vehicle location and GPS tracking information is retained for a period of one year. Following this period, the information will be securely deleted or otherwise disposed of in accordance with our data retention procedures, unless a longer retention period is required by law or agreed with the relevant customer.

Account information: Account information is retained for the duration of the relevant business relationship and for any additional period required for legitimate business, legal or regulatory purposes.

Payment information: Payment-related records may be retained for the periods required to meet applicable financial, accounting and legal obligations.

Where information is no longer required, it will be securely deleted or anonymised where appropriate.

10. Your data protection rights

Where information we process relates to an identifiable individual, that individual may have rights under applicable data protection legislation.

These rights may include:

The right to access personal information.

The right to request correction of inaccurate information.

The right to request deletion of personal information.

The right to restrict certain processing.

The right to object to certain processing.

The right to data portability, where applicable.

The right to withdraw consent where processing is based on consent.

These rights are subject to applicable legal conditions and exemptions.

Where SquareLabs processes information on behalf of a business customer, requests relating to that information may need to be directed to the relevant business customer as the data controller.

To exercise applicable rights in relation to information for which SquareLabs is the data controller, please contact us using the details in this policy.

11. Cookies and tracking technologies

Our website does not use advertising cookies, marketing cookies or third-party advertising trackers.

We do not display advertisements or use advertising networks on our website.

We use Google Analytics for general website traffic analysis and to understand overall website usage.

We do not intentionally use website analytics to identify individual visitors.

Where any analytics cookies or similar technologies are used, we will provide appropriate information and obtain consent where required by applicable law.

12. Mobile application

Our mobile application provides access to SquareLabs' Fleet services.

The application is intended for business customers and authorised company users.

The app is not designed as a driver-facing application and does not require drivers to register individual accounts or provide personal driver profiles.

Vehicle location information is obtained through connected tracking and IoT hardware rather than requiring drivers to use the application to submit their location.

The app may process account authentication information and technical information necessary to provide access to the service.

Any additional permissions or information collected by future app functionality will be explained appropriately and this policy will be updated where necessary.

13. Children's privacy

Our services are intended for businesses and authorised business users.

They are not designed or marketed to children, and we do not knowingly collect personal information from children through our services.

14. Changes to this policy

We may update this Privacy Policy from time to time to reflect changes to our services, technology, legal obligations or business operations.

The latest version will be made available on our website, together with the date it was last updated.

Where changes materially affect how personal information is processed, we will take appropriate steps to notify affected individuals or customers.

15. Contact us

If you have questions about this Privacy Policy, how we handle information or wish to exercise your applicable data protection rights, please contact:

SQUARELABS LIMITED 6 The Beech Tree Elmhurst Business Park Lichfield Staffordshire England WS13 8EX

Email: [email protected] Telephone: +44 (0)3300 88 2708 Website: https://fleet.squarelabs.uk

16. Right to complain

If you are unhappy with how we have handled your personal information, we would encourage you to contact us first so that we can investigate your concerns.

You also have the right to complain to the UK Information Commissioner's Office (ICO):

Website: https://ico.org.uk Telephone: 0303 123 1113