Privacy Policy

Version 3 · 3 October 2026

This is a translation. The Portuguese version (Política de Privacidade) is the one that applies.

This policy explains what personal data we process in the TVDE Driver app and on the tvdedriver.pt site, why, who we share it with, how long we keep it, and how you can exercise your rights. We wrote it from what the app actually does, not from a template.

1. Who is the controller

The controller is Libelinha Lilaz, Lda., Portuguese company number (NIPC) 519531400 («we»), which provides the TVDE Driver app and the tvdedriver.pt site.

For anything about your data: [email protected]. We have not appointed a data protection officer (DPO).

2. What this covers

• The TVDE Driver app, for TVDE (ride-hailing) drivers who manage their own work, on the phone and in the web version;
• the tvdedriver.pt site.

In the app, the person whose data we process is the driver.

3. What data we process

What the app does not do: it does not ask for your location, has no advertising or usage tracking inside the app, and does not sell or rent data to anyone.

4. Why, and on what legal basis

Performance of a contract (GDPR art. 6(1)(b)) — to provide the service you asked for when you created your account:

• to create and manage your account and sign-in;
• to record earnings, expenses and extra income, and calculate balances, reports and the weekly goal;
• to store your documents and your vehicle's and warn you before they expire;
• to read documents automatically and fill in dates and fields (section 5);
• to record working time on the time clock, warn you at 9 hours in any 24 and at 55 hours in the week, and produce the PDF of your working-time record;
• to answer your help requests and send you account notifications.

Legitimate interest (art. 6(1)(f)) — keeping the service safe and working: logging administration actions, suspending accounts used abusively, keeping track of the cost of AI readings, and protecting the site against abuse.

Consent (art. 6(1)(a)) — phone notifications (which your phone asks you to allow) and measurement and advertising on the site (section 11). You can withdraw consent at any time, without affecting what was done before.

Legal obligation (art. 6(1)(c)) — responding to requests from authorities entitled to make them.

Driver documents include the criminal record certificate. We store it only because the driver wants to keep it in the app and be warned about its validity; we do not analyse it or use it to decide anything.

5. AI reading of documents

When you upload a document, the app may send the image to an artificial intelligence model from Anthropic to read the expiry date and other fields (for example, the tax number or address).

• Only the image of the document you chose to read is sent, and nothing else from your account.
• The result is a suggestion: it is shown to you to check, and you can correct it. The reading does not decide anything about you — there is no automated decision-making with legal effects (GDPR art. 22).
• A pre-reading awaiting your confirmation is deleted after 1 day.
• Anthropic is a US company: see section 7.

6. Who has access

Your data is yours: in the app, each person only sees their own.

TVDE Driver administration sees the list of accounts and, for each one: email, name, creation date and last sign-in, company and whether its RNAAT is valid, vehicle registration plate, how many documents and earnings entries it has, the date of the last earnings entry, how many AI readings it made in the last 30 days, the date of the closure request, and, if the account is suspended, the reason. It does not see each person's earnings amounts — only totals added up across all accounts. It reads and answers help messages, and can:

• suspend an account (with a reason only administration sees) and reactivate it;
• waive missing documents for 30 days: during that period the app stops asking for them. It does not approve or validate any document; when the period ends, whatever is missing is asked for again.

The administration page does not give access to your documents.

Processors — companies that process data on our behalf, only for the stated purpose:

We do not sell data or share it with third parties for advertising. Google and Meta receive, from the site and only with consent, just the browsing data described in section 11 — never data from your app account.

7. Transfers outside the EEA

The database and files are stored in the European Union. Some processors — Anthropic and, depending on the service, Google, Meta, Cloudflare and Resend — may process data outside the European Economic Area, mainly in the USA. In those cases the transfer relies on the European Commission's adequacy decision for companies certified under the EU-US Data Privacy Framework, or on standard contractual clauses approved by the European Commission. You can ask us for more information about these safeguards.

8. How long

• While your account exists, we keep your account data and what you recorded, to provide the service.
• AI pre-readings not yet confirmed: deleted after 1 day.
• Notifications already read: deleted after 6 months.
• Replaced files (for example, when you change vehicle or delete an entry with a receipt): deleted shortly afterwards.
• Closing your account: you have 30 days to change your mind. After those 30 days access is blocked, and 1 year later we delete the account's data and files. We keep that year in case you need to recover a record or an authority makes a request; before closing, you can export everything (section 9).
• Site: cookie periods are in section 11.

After deletion, data may still exist in our providers' backups until those are replaced in their normal cycle.

9. Your rights

You have the right to access your data, correct it, request erasure, restrict or object to processing, data portability, and to withdraw consent. In the app you can already, without asking us:

• export your records — on the «My records» screen, as a ZIP file with your data and documents;
• correct your data in your profile and documents;
• close your account, with 30 days to change your mind.

For anything else, write to [email protected]. We reply within one month. We may ask you to confirm your identity before replying.

10. Security

• Every table with personal data has access rules in the database itself: each person can only read and write their own.
• Documents are kept in private file storage, with no public addresses.
• Everything travels encrypted (HTTPS). Sign-in uses a code sent by email or your Google account; we store no passwords.
• Service keys stay on the server, never in the app.

11. Cookies and measurement on the site

The app uses no cookies or usage tracking. What follows is only about the tvdedriver.pt site.

Always on, with no cookies: Cloudflare Web Analytics counts visits without setting cookies and without identifying visitors.

Only with your consent, which we ask for in a bar when you open the site and which you can give or refuse per category:

• Traffic analysis (Google Analytics 4) — which pages are viewed, from where and on what kind of device. Cookies _ga and _ga_*, up to 2 years.
• Advertising measurement (Google Ads and Meta pixel) — whether an ad on Google, Facebook or Instagram brought the visit. They receive the page address, technical browser data, your IP address and the identifier of the ad you clicked. Cookies _gcl_*, _fbp and _fbc, up to 90 days.

None of this loads before you choose. Refusing is one click, just like accepting. Your choice is kept in your browser for 12 months; if you withdraw consent, we delete that category's cookies.

At the moment the site uses none of these services, so it shows no consent bar.

12. Minors

The app is for TVDE drivers, who are necessarily adults. We do not knowingly collect data from minors.

13. Changes to this policy

Each version has a number and a date, and is recorded in the history below. When a change is substantial, the app will ask you to accept it again the next time you sign in, with a sentence saying what changed.

The Portuguese version is the one that applies; this English version is a translation.

14. Contact and complaints

To exercise your rights or ask a question: [email protected].

You also have the right to lodge a complaint with the Comissão Nacional de Proteção de Dados (www.cnpd.pt), the Portuguese supervisory authority.

15. Version history