Platform privacy notice

When a company contracts Drometra and installs devices in its fleet, that company decides what to measure, for what and for how long. Drometra is responsible for the treatment. Drometra runs this treatment on its own and under its documented instructions: it is the one in charge.

The distinction is not formal. It determines who must inform drivers, who answers a request for access, who defines the retention time limits and who responds to the Agency if the treatment is excessive. A supplier who presents himself as a simple technical intermediary and then uses the data for its own purposes ceases to be responsible and becomes responsible, with all the obligations that this implies. We do not cross that line, and this document exists so that you can verify it.

It depends on what the client contracts and activates. No module is turned on alone. This is the whole of what the platform can deal with.

We do not process audio, do not perform facial recognition, do not generate biometric templates, and there is no driver-facing cab camera. If any of those features were ever offered, it would require a prior impact assessment, an update to this notice, and express activation by the customer.

• We treat them only to provide the service: operate the intake, normalize, store, show, alert, report and expose by API what the client configured.
• We don't use them for our own purposes.: We don't sell them, we don't give them up, we don 't build data products on one client's operation, we don "t reveal it to another.
• We don't mix them between customers.: The tenant is the border of isolation. The same RUT present in two tenants does not authorize sharing of chips, prices or evidence between them.
• We do not train models with them: neither our own nor third parties'. Any model improvement using a customer's data would require a specific, written, and revocable agreement, and is never the default setting.
• We will not access the content unless necessary.: access by Drometra personnel to a customer's data requires a documented cause —an incident, an authorized migration— which the customer may request.

If the client instructs us something that we believe is in violation of the data protection law, we warn you in writing before we execute it and we make it clear. It is not a discretionary power: it is the only way for the sharing of responsibilities to mean something.

The platform is delivered with the least invasive configuration compatible with the contracted service. Expanding the capture is an explicit decision of the client, not a value that was already in place.

Most of the data that pass through the platform are from our customers' workers. In Chile, this adds a layer of demand on data protection: the control of the employer has its own limits in the Labour Code and in the doctrine of the Labour Directorate.

The Directorate of Labour has consistently held that the mechanisms of audiovisual control and positioning are only lawful when they are objectively justified by technical requirements of the production process or for safety reasons, they must be impersonal and general, and the control of the activity of the worker must be a secondary result and not the purpose of the system. They must also be included in the internal regulations and known to the workers.

Applied to operations: using positioning or video to monitor individual performance is a use the doctrine does not support; using them to prevent accidents, coordinate deliveries, and support a safety program, disclosed and with known rules, is. Responsibility for that decision lies with the customer, but we make it visible and provide the tools to comply with it. The full discussion is in the document on driver data.

Michiva answers questions about the customer's operations. Today it answers a limited set of predefined questions using its own rules, without external models. When the customer enables the language model layer, the question and the facts needed to answer it are sent to an OpenAI or Anthropic model via API, directly or through OpenRouter.

• What is sent: the written question, the vehicle labels with license plates masked and, when drafting, already calculated figures with the names of vehicles, customers, warehouses, and drivers replaced by placeholders.
• What we require of the provider: that it not use the data for training and, when the model allows it, zero retention. If the model does not support zero retention, the provider may keep abuse-monitoring logs for up to 30 days; we disclose this before enabling it.
• What we store: only a usage log —user, purpose, model, result, consumption, and cost— which is deleted after 90 days. We do not store the text of the question or the answer.
• What the model does not do: it does not calculate figures, does not execute actions on operations, and does not make decisions about people. Every action with an effect will require explicit confirmation from a user.
• What's coming: alerts, driving analysis, WhatsApp messages to recipients and route change proposals will process fleet and recipient data on the customer's behalf, only if its administrator turns them on. Their rules are in the document on Michiva.

The database volume on the server is not encrypted at the disk level; this is under evaluation. The other guarantees in this notice do not depend on that measure, but we prefer to disclose it.

To provide the service we rely on a numbered number of suppliers. Each one is under contract with the same obligations we assume, and the complete list - with function, company, country and implication for the data - is published and versioned in the register of sub-commissioned.

Before incorporating a new sub-manager, we have advised the customers who have signed up to the register 30 days in advance. During this period, the client can object in writing on a basis; if we do not reach a solution, he can end the service concerned without penalty.

If we detect a violation that affects personal data treated on behalf of a client, we notify them without undue delay and no later than 24 hours from the time we confirm it, as we know at that time: the nature of the incident, categories and approximate volume of data and of holders, likely consequences and measures taken or proposed.

The notification to the Agency and to the holders concerned is the responsibility of the client, who is responsible, and we give him all the information and assistance he needs to do so in a timely manner. We do not condition such assistance to any negotiation on the incident.

When the contract ends, the customer chooses between return or deletion. Today this process is not automated: our team carries it out upon the customer's written request, with the following commitments.

1. 1.For 60 days from termination, the customer can export orders and deliveries from the console or request a complete delivery in a structured format.
2. 2.Once the erasure instruction is received at [email protected], or once 60 days have passed without instructions, we delete the data from active systems within 30 days.
3. 3.Encrypted backup copies are deleted when they are rotated. Automatic backup rotation is being implemented, with a target of 30 days; in the meantime, backup deletion is done manually and documented.
4. 4.We issue a deletion certificate when the client requests it.

We keep beyond those time limits only what a legal obligation requires - tax records, for example - and in that case we indicate what is retained and under what rule.

You have the same rights as any holder: access, rectification, suppression, opposition, portability and blocking. The particularity is who you ask.

1. 1.It addresses the application to your employer, who is responsible for the treatment and who decides on the data.
2. 2.If you don't know who to write to, or you don't get an answer, write to [email protected]. We identify the person responsible and transfer your application within a maximum of 5 working days, and we confirm that we did.
3. 3.We cannot delete or modify data that belong to a customer's operation on our own initiative: to do so would be to treat the data outside of your instructions. We can - and do - credit what data exists and make it easier to resolve.
4. 4.If you consider the treatment to be illegal, you can claim directly with the Personal Data Protection Agency, without exhausting any previous steps.

No request from you leads us to inform your employer that you submitted it, beyond what is strictly necessary to process it.