Car 2 Home Location Information Consent

Version 1.1, effective May 5, 2026

For questions, please contact us at:

• Website: www.car2home.ai
• Privacy: privacy@car2home.ai
• Support: support@car2home.ai

Article 1. Purpose

① This Agreement establishes the terms under which the Company collects, stores, uses, and shares location information in connection with the Car 2 Home Service, in compliance with applicable Brazilian and international law, including:

• Lei Geral de Proteção de Dados Pessoais (LGPD, Lei nº 13.709/2018)
• Marco Civil da Internet (Lei nº 12.965/2014)
• Consumer Defense Code (CDC, Lei nº 8.078/1990)
• General Data Protection Regulation (GDPR, EU Regulation 2016/679), where applicable to members located in the European Economic Area.

② The Company collects location information solely to provide and improve the features of the Car 2 Home Service, as described in this Agreement and the Privacy Policy available at www.car2home.ai.

Article 2. Effectiveness and Amendments

① This Agreement becomes effective when the Member explicitly agrees to its terms during the registration or in app consent process.

② By consenting to the collection and use of location information through the Company's website or application, the Member is deemed to have read, understood, and agreed to the contents of this Agreement.

③ The Company may amend this Agreement within the scope permitted by applicable law, including the LGPD and the CDC. Amendments will be announced on the initial screen of the Service at least 30 days prior to the effective date, with the reasons for revision clearly stated. For amendments unfavorable to Members, additional individual notification will be sent via email or in app notification.

④ If the Company announces an amendment with notice that silence will be deemed as consent and the Member does not express explicit refusal within the notice period, the Member shall be deemed to have agreed to the revised Agreement.

⑤ Members have the right to refuse amended terms. If they do not agree, they may cease using location based features and may terminate the service contract with the Company.

Article 3. Applicable Laws

Matters not specified in this Agreement shall be governed by the following:

• LGPD (Lei nº 13.709/2018), General Data Protection Law (Brazil)
• Marco Civil da Internet (Lei nº 12.965/2014), Internet Civil Rights (Brazil)
• CDC (Lei nº 8.078/1990), Consumer Defense Code (Brazil)
• Decreto nº 7.962/2013, Electronic Commerce Regulation (Brazil)
• GDPR (EU Regulation 2016/679), for members located in the European Union
• The Company's Privacy Policy and Terms of Service

In the event of conflict between these laws and this Agreement, applicable law shall prevail.

Article 4. Contents of Location Based Services

① The Company uses location information to provide the following features within the Car 2 Home Service:

• Trip recording: capturing GPS routes and distances traveled per trip;
• Driving history and statistics: aggregating routes, travel time, and mileage over time;
• Real time vehicle location display within the App;
• Home automation integration: transmitting location based events (such as vehicle departure or arrival) to the Member's personal home automation server (for example, Home Assistant) via the native Home Assistant transport (default option) or MQTT, as configured by the Member.

② Service availability and delivery methods may change, be delayed, or become unavailable depending on the Company's operational or technical circumstances. The Company will provide advance notice where possible.

③ Location data transmitted to the Member's personal home automation server is sent exclusively to the server address configured by the Member within the App. The Company does not have access to or store this data on its own infrastructure. The security of that transmission is the Member's responsibility, as described in the Privacy Policy and Terms of Service.

Article 5. Service Fees

① Location based features are included in both the free and paid tiers of the Car 2 Home Service. Premium features may require a paid subscription.

② Payments for paid services are processed through the Google Play Store (Android) and the Apple App Store (iOS). Cancellations and refunds are governed by Article 20 of the Car 2 Home Terms of Service and applicable law.

③ Data charges incurred during the use of location services over mobile networks are separate and subject to the policies of each member's mobile carrier.

Article 6. Collection, Use, and Retention of Location Information

① The Company will request the Member's explicit consent before collecting or using personal location information. This consent is requested during the App's onboarding process or when location dependent features are first accessed.

② The Member may grant or revoke consent to location data collection at any time through the App's settings or the device's operating system location permissions. Revoking consent may render certain features of the Service inoperable.

③ The Company records and retains logs of location data collection and usage for a period of up to 1 (one) year for service operation and complaint handling purposes, after which the data is deleted or anonymized. Anonymized and aggregated statistical data may be retained for service improvement purposes.

④ The legal basis for processing location data under the LGPD is the Member's explicit consent (Art. 7, I) and, where applicable, the performance of the service contract (Art. 7, V). Under the GDPR, the legal basis is explicit consent (Art. 6(1)(a)) and contract performance (Art. 6(1)(b)).

Article 7. Third Party Provision of Location Information

① The Company does not provide personal location information to third parties without the Member's prior and explicit consent. When integration with third party services requires sharing location information, the recipient, purpose, and scope will be disclosed and consent obtained in advance.

② Exceptions to the consent requirement include:

• When required by applicable Brazilian law or by order of a competent court or public authority;
• When necessary for the protection of life or physical safety and consent cannot be obtained in time.

③ When location information is provided to a third party with the Member's consent, the Company will notify the Member of the recipient, the time of provision, and the purpose, via the App or email.

④ The Company is not responsible for consequences arising from the Member failing to review or act upon such notifications.

Article 8. Rights of the Member Regarding Location Information

① Members may withdraw consent to the collection and use of their location information at any time, without penalty, through the App settings or by contacting privacy@car2home.ai. Withdrawal of consent does not affect the lawfulness of processing carried out prior to the withdrawal.

② Members may request a temporary suspension of the collection, use, or provision of their location information. The Company cannot refuse such a request and maintains technical mechanisms to honor it.

③ Members may request access to, or a summary of, the following records, and may request correction if any information is inaccurate. The Company cannot refuse such requests without just and lawful cause:

1. Records of collection, use, and provision of their location information;
2. Reasons and details of any provision of location data to third parties.

④ Rights under this Article may be exercised by contacting privacy@car2home.ai or through the account settings within the App.

⑤ Members located in Brazil also have the rights established in Art. 18 of the LGPD, including access, correction, deletion, portability, and revocation of consent. Members in the EU have equivalent rights under Art. 15 to 22 of the GDPR.

Article 9. Minimum Age

① The Car 2 Home Service, including location based features, is intended for users who are at least 18 (eighteen) years of age. The Company does not knowingly collect location information from individuals under the age of 18.

② If the Company becomes aware that location data has been collected from a minor, it will promptly delete such data and terminate the associated account.

Article 10. Non Assignment

Members may not transfer, donate, or use their rights under this Agreement as collateral or in any other way assign them to a third party.

Article 11. Compensation for Damages

① If the Company fails to comply with applicable data protection law or the terms of this Agreement and causes damage to a Member, the Member may claim compensation, unless the Company demonstrates that the damage did not result from intentional or negligent conduct on its part.

② If the Member violates this Agreement and causes damage to the Company, the Company may claim compensation, unless the Member demonstrates the absence of intent or negligence.

③ Claims for damages must be submitted in writing (including by email) stating the reason, the amount claimed, and the basis of calculation, to privacy@car2home.ai.

Article 12. Disclaimer

① The Company is not responsible for damages arising from:

1. Natural disasters, war, civil unrest, or other force majeure events;
2. Intentional interference by a third party service provider beyond the Company's control;
3. Fault or negligence attributable solely to the Member;
4. Failure, inaccuracy, or unavailability of GPS signals or device sensors, which are provided by the device manufacturer and mobile network operators;
5. Any service interruption or data loss caused by the Member's OBD terminal device, which is owned and managed by the Member or a third party manufacturer.

② The Company does not guarantee the absolute accuracy or real time precision of location data, as this depends on external factors such as GPS satellite availability, device hardware, and network conditions. Location data is provided for informational and personal convenience purposes only and is not intended for safety critical, professional, or navigation use.

Article 13. Dispute Resolution and Jurisdiction

① The Company will make every effort to resolve disputes with Members through good faith consultation.

② If a dispute cannot be resolved through direct negotiation within 30 days, the Member may submit the matter to:

• The Brazilian National Data Protection Authority (ANPD): www.gov.br/anpd
• The Brazilian Consumer Protection System (Procon) of the Member's state;
• The online dispute resolution platform consumidor.gov.br (Brazil).

③ If the dispute remains unresolved after the steps above, it shall be brought before the Courts of the District of São Paulo, State of São Paulo, Brazil, which are elected as the exclusive forum for any legal proceedings arising from this Agreement, in accordance with Article 13 of the Car 2 Home Terms of Service.

④ Members located in the European Union retain the right to file a complaint with their local supervisory authority under the GDPR, and to seek resolution through their local consumer protection bodies.

Appendix 1. Company Information

This Agreement supersedes all previous versions.

© 2026 VS1 Software Ltda. All rights reserved.
www.car2home.ai