Privacy Policy

Version 2.0 · Effective from 22 October 2026

This Policy explains what personal data the Golden Sat Waker App collects, what we use it for, with whom we share it, how long we keep it and how you can exercise your rights. It complies with the Lei Geral de Proteção de Dados (Law No. 13.709/2018 – LGPD – Brazilian General Data Protection Law), the European Union General Data Protection Regulation (Regulation (EU) 2016/679 – GDPR), the UK GDPR, the Swiss Federal Act on Data Protection and the state privacy laws of the United States.

1. Summary

TopicIn a nutshell
Who processes the dataGolden XW Sistemas Inteligentes Ltda. For Drivers linked to a company, the company decides on the operation data and we process it on its behalf.
Main dataRegistration details, location (including in the background), camera images during the Operation, driving events, vehicle and device data.
What forTo alert you to fatigue and distraction, record the Operation, generate reports, navigate with Waker Maps, charge subscriptions and comply with the law.
Sale of dataWe do not sell your personal data.
Where it is storedServers in Brazil, with some technology providers abroad.
Your rightsAccess, rectification, erasure, portability, objection, withdrawal of consent and review of automated decisions, by e-mail at suporte@wakerapp.com.br.

2. Who we are and how to contact us

2.1. Controller: GOLDEN XW SISTEMAS INTELIGENTES LTDA., CNPJ (Brazilian company registration) No. 63.932.482/0001-38, Rua Haiti, nº 129, Parque das Nações, Santo André/SP, CEP 09280-390, Brazil (“Golden Sat”, “we”, “us”).

2.2. Data Protection Officer (Encarregado – DPO): GOLDEN XW SISTEMAS INTELIGENTES LTDA., contact by e-mail at suporte@wakerapp.com.br, with the subject “Privacy”.

2.3. Users in the European Union and the United Kingdom: until a representative is appointed under Art. 27 GDPR, requests may be sent directly to the e-mail address above. This Policy will be updated once the representative is appointed.

3. Role of each party

4. Data we collect

CategoryExamplesSource
Registration and accountName, nickname, e-mail, telephone number, CPF (Brazilian individual taxpayer number, when provided), profile photo, company and roleYou, the Contracting Company or the sign-in service you choose
LocationPrecise position, speed, heading and route, including while the app is in the backgroundThe phone’s GPS and sensors
Camera imagesContinuous analysis of the front camera during the Operation; front and rear photos of risk events; front photo at the start and end of the Operation and upon acceptance of these documentsThe phone’s cameras
Driving eventsProlonged blinks, yawns, drowsiness, distraction, phone use, lens obstruction, speeding, with date, time and locationArtificial intelligence processing on the phone
Telemetry and sensorsAcceleration, braking, movement, activity recognition (for example, “in vehicle”) and distance travelledThe phone’s sensors
Operation and working hoursStart, end, breaks, stops, responses to the activation reminder (“I am a passenger”, “I am not working”, no response)Use of the App
VehicleLicence plate, model, body type, height, length, weight, axles and loadYou or the Contracting Company
Waker MapsOrigin, destination, saved routes, reports, text or voice contributions, approximate position shown to nearby driversYou and use of the App
VoiceSpoken commands and dictation, converted into textMicrophone, when you trigger dictation
Device and usageModel, operating system, App version, device identifier, IP address, access and error logs, notification tokenAutomatic collection
PaymentsPlan, status, dates and subscription receipts. We do not receive your card details.Application store or Contracting Company
AdvertisingDevice advertising identifier (Waker Maps Basic plan)Advertising partner
SupportMessages and information sent to supportYou
Acceptance recordDocument version and hash, date and time, IP, device, geolocation, front photo and facial landmarks (face mesh)You, at the time of acceptance

4.2. Mandatory and optional data. Unless otherwise indicated, the data requested are necessary to provide the Services. Without them, some features will stop working. Where an item of data is optional, the App will indicate this at the time of collection.

4.3. Other people’s data. If you send us data relating to third parties, for example in reports, photos or contributions, you declare that you are authorised to do so and you are responsible for sending it.

5. Sensitive data and facial images

5.1. To detect fatigue, the App analyses facial landmarks (such as how open the eyes and mouth are) on the phone itself, in real time. This processing does not identify who you are and the continuous images are not sent to our servers. Only photos of risk events and photos at the start and end of the Operation are sent. When you accept the Terms of Use and this Policy, we also send a photo and the facial landmarks (face mesh), solely to evidence acceptance.

5.2. We do not use facial recognition to identify people. Even so, as facial images and signs of drowsiness may be considered sensitive data (biometric or health-related data), we apply enhanced protection to them.

5.3. The lawful basis for such data is, as the case may be: the protection of the life and physical safety of the Driver and third parties (Art. 11, II, (e), LGPD); the regular exercise of rights and compliance with a legal obligation by the Contracting Company (Art. 11, II, (a) and (d)); or your specific consent (Art. 11, I). In the European Union, we process special categories of personal data with your explicit consent (Art. 9(2)(a) GDPR) or, where applicable, for obligations in the field of employment law and safety (Art. 9(2)(b)).

5.4. We do not collect data from health apps on your phone.

6. What we use the data for and on which lawful basis

PurposeLawful basis (LGPD / GDPR)
Creating and maintaining your account, authenticating access and providing the ServicesPerformance of a contract (Art. 7, V / Art. 6(1)(b))
Detecting fatigue, drowsiness and distraction and issuing alertsProtection of life and physical safety; performance of a contract; consent where required (Arts. 7, VII and 11, II, (e) / Arts. 6(1)(b) and 9(2)(a))
Recording the Operation, events, telemetry and route and generating reports and the Driver ProfilePerformance of a contract; legitimate interests of the Contracting Company in fleet safety (Art. 7, V and IX / Art. 6(1)(b) and (f))
Reminding the Driver to activate the Operation when the vehicle is moving and reporting the response to the Contracting CompanyLegitimate interests in road and fleet safety; performance of a contract (Art. 7, IX and V / Art. 6(1)(f) and (b))
Waker Maps navigation, routes and alertsPerformance of a contract (Art. 7, V / Art. 6(1)(b))
Showing nearby drivers on the mapLegitimate interests, with display without name and with approximate position (Art. 7, IX / Art. 6(1)(f))
Ads in the Waker Maps Basic planLegitimate interests, with the option to limit the advertising identifier in your phone’s settings; consent where required by law, such as in the European Union and the United Kingdom (Art. 7, IX and I / Art. 6(1)(a))
Billing, issuing invoices and tax obligationsCompliance with a legal obligation; performance of a contract (Art. 7, II and V / Art. 6(1)(c) and (b))
Keeping access logs for the legal periodCompliance with a legal obligation – Marco Civil da Internet (Brazilian Internet Civil Framework), Art. 15 (Art. 7, II / Art. 6(1)(c))
Recording and evidencing acceptance of the Terms and this PolicyRegular exercise of rights; compliance with a legal obligation (Art. 7, VI and II / Art. 6(1)(c) and (f))
Security and prevention of fraud and misuseLegitimate interests (Art. 7, IX / Art. 6(1)(f))
Support and communications about the servicePerformance of a contract; legitimate interests (Art. 7, V and IX / Art. 6(1)(b) and (f))
Improving the algorithms and the service, using anonymised or statistical dataLegitimate interests (Art. 7, IX and Art. 12 / Art. 6(1)(f))
Defence in judicial, administrative or arbitration proceedingsRegular exercise of rights (Art. 7, VI / Art. 6(1)(f))

7. Automated decisions and profiling

7.1. The indicators, the safety score and the Driver Profile are generated automatically from driving events. They serve to inform and to prevent risks.

7.2. Golden Sat does not take decisions producing legal effects concerning you based solely on these indicators. Management decisions are made by the Contracting Company.

7.3. You may request information about the criteria used and the review of decisions taken solely on the basis of automated processing (Art. 20 LGPD and Art. 22 GDPR).

8. With whom we share data

8.1. The Contracting Company and its Managers, when you are linked to it: events, event images, photos at the start and end of the Operation, routes, reports, responses to the activation reminder and vehicle data.

8.2. Monitoramento Golden (Golden Monitoring), when contracted by the Company: the monitoring centre accesses the location and events of the trip in order to follow it.

8.3. Insurers and risk management companies, only when the Contracting Company authorises the display of the reports of its trips.

8.4. Providers that process data on our behalf, under contract and subject to confidentiality and security obligations, grouped by category:

Provider categoryServiceLocation
Cloud infrastructure and databaseDatabase, authentication, file storage and server functionsBrazil
Application server hostingRouting and map serversBrazil or abroad, as per the hosting contract
Map, route planning and place imagery providersTruck route calculation, maps, traffic and place imagery (they receive coordinates and the vehicle profile, without your name)Abroad
Operating system platforms and app storesApp distribution, subscription billing, sign-in, notifications and speech recognitionAbroad
Advertising partnerAds in the Waker Maps Basic planAbroad

8.4.1. We require these providers to protect the data to a standard equal to or higher than that provided for in this Policy and by law.

8.4.2. For information security reasons, we do not publicly disclose the names of our providers. You may request them from the Data Protection Officer at the e-mail address in Section 2, and they will be provided once your identity has been confirmed (Art. 18, VII, LGPD and Art. 15(1)(c) GDPR).

8.5. Authorities, when required by law, court order or request from a competent authority, and to defend our rights.

8.6. Corporate transactions: in the event of a merger, acquisition or sale of assets, the data may be transferred to the successor, which will be bound by this Policy.

8.7. We do not sell personal data and do not share it for cross-context behavioural advertising, except for the advertising identifier used by the advertising partner to display ads in the Waker Maps Basic plan, which you can limit or reset in your phone’s settings.

9. International transfers

9.1. Our main servers are located in Brazil. Some technology providers process data in other countries.

9.2. These transfers are based on the standard contractual clauses approved by the ANPD (Brazilian Data Protection Authority) (Resolução CD/ANPD nº 19/2024), the European Commission’s Standard Contractual Clauses, adequacy decisions or the other grounds set out in Art. 33 LGPD and Chapter V GDPR.

9.3. For users in the European Union, the transfer of data to Brazil takes place on the basis of the Standard Contractual Clauses or, where applicable, because it is necessary for the performance of the contract with you (Art. 49(1)(b) GDPR).

10. How long we keep data

DataRetention period
Account and registrationWhile the account is active and up to 5 years after it is closed, for the defence of rights
Events, event images, Operation photos, routes and reportsFor the term of the contract with the Contracting Company or of the individual subscription and up to 1 year after it ends, unless otherwise instructed by the Company or required by law
Position shown to nearby driversOnly while you are using the map; the position is overwritten with each update and no history is kept
Access logs (date, time and IP)At least 6 months, in accordance with Art. 15 of the Marco Civil da Internet
Tax and billing data5 years, in accordance with tax legislation
Records of acceptance of the Terms and this PolicyWhile the account exists and up to 5 years after it is closed, as evidence in any proceedings
Contributions and reports on Waker MapsFor as long as they are useful to the map; they may be kept in anonymised form

10.2. Once the period has expired, the data are erased or anonymised, except where the law permits or requires their retention (Art. 16 LGPD).

11. Security

11.1. We adopt technical and organisational measures to protect the data, such as encryption in transit, role-based access control, security rules in the database, private storage of images and audit logs.

11.2. No system is completely secure. If a security incident occurs that may cause significant risk or harm, we will notify you and the competent authorities within the time limits set by law.

11.3. Within Golden Sat, the data are accessed only by authorised persons, such as the support, operations, systems administration and legal teams, to the extent necessary for their duties and subject to a duty of confidentiality.

12. Your rights

12.1. Under the LGPD (Brazil), you may request: confirmation that we process your data; access; correction of incomplete, inaccurate or outdated data; anonymisation, blocking or erasure of unnecessary or excessive data or data processed in breach of the law; portability; erasure of data processed on the basis of consent; information about with whom we share data; information about the possibility of not giving consent and the consequences of refusal; withdrawal of consent; objection to unlawful processing; and review of automated decisions.

12.2. Under the GDPR (European Union, EEA and United Kingdom), you have the rights of access, rectification, erasure, restriction of processing, portability, objection (including to processing based on legitimate interests), withdrawal of consent at any time and not to be subject to decisions based solely on automated processing with significant effects.

12.3. How to exercise them: send an e-mail to suporte@wakerapp.com.br. We may ask for information to verify your identity. This service is free of charge.

12.4. Time limits: we respond immediately in simplified form or within 15 days in full (LGPD). For users in the European Union, within one month, extendable in the cases provided for in the GDPR.

12.5. Complaints: you may lodge a complaint with the Brazilian National Data Protection Authority (ANPD), with the data protection supervisory authority of your country in the European Union, with the Information Commissioner’s Office (ICO) in the United Kingdom, or with consumer protection bodies.

12.6. If you are a Driver linked to a Contracting Company, some requests depend on it, as the controller. In such cases, we will forward the request and let you know.

12.7. Exercising your rights will never result in discrimination.

12.8. When we rectify, erase or restrict data at your request, we will communicate this to the recipients with whom we have shared the data, unless this proves impossible or involves disproportionate effort. If you so request, we will tell you who those recipients are.

12.9. Deletion of the account and data. You can request deletion in three ways: in the App, under Settings › Privacy › Delete my account; through the account deletion form; or, if you only want to delete part of your data and keep the account, through the data deletion form. We also handle requests by e-mail at suporte@wakerapp.com.br, with the subject “Delete account”, sent from the e-mail address registered to your account. We will confirm the request and complete the deletion within 15 days. Only the data that the law requires or permits us to keep are retained, for the periods set out in Section 10: access logs (at least 6 months), tax data (5 years) and records of acceptance of these documents (5 years). If you are a Driver linked to a Contracting Company, its operation data follow the Company’s instructions.

13. Phone permissions

PermissionWhat it is used for
CameraDetecting fatigue and distraction, taking photos of events, of the start and end of the Operation and of acceptance
Location, including in the backgroundRecording routes and events, navigating, detecting movement without an active Operation and recording acceptance
Physical activity and motion sensorsIdentifying that you are in a vehicle and measuring acceleration and braking
MicrophoneVoice dictation in Waker Maps, only when you trigger it
NotificationsAlerts, activation reminders and service notices
Display over other apps, battery optimisation and screen brightnessKeeping alerts visible and monitoring active during the trip
App storage on the phoneStoring events, photos and routes while there is no internet connection, until they are synchronised; these files are kept in the App’s private storage area
Bluetooth and audioPlaying alerts through the vehicle’s sound system or connected accessories

13.2. You may revoke permissions in your phone’s settings. Without some of them, essential features, such as fatigue detection, will stop working.

14. Cookies and similar technologies

14.1. The App does not use browser cookies, but it does use device identifiers and identifiers of third-party software components in order to function, measure crashes and, in the Waker Maps Basic plan, display ads.

14.2. You can limit or reset the advertising identifier in your phone’s privacy settings. Our legal document web pages use only strictly necessary resources.

15. Children and adolescents

The App is intended for persons over 18 years of age. We do not knowingly collect data from minors. If we identify such data, it will be erased.

16. Additional information for users in the European Union, the EEA, the United Kingdom and Switzerland

16.1. This section supplements the Policy and, for these users, prevails over any conflicting information.

16.2. The applicable lawful bases are set out in Section 6. Where processing is based on consent, you may withdraw it at any time, without affecting the lawfulness of processing carried out before its withdrawal.

16.3. Where processing is based on legitimate interests, you may object on grounds relating to your particular situation. We do not carry out direct marketing with your data; should we start doing so, you may object at any time, without giving reasons.

16.4. The data required to create the account and provide the Services are necessary for the performance of the contract. Without them, we are unable to provide the Services.

16.5. Users in Switzerland have the rights provided for in the Federal Act on Data Protection (nFADP), including access, rectification, objection, portability and the right to lodge a complaint with the Federal Data Protection and Information Commissioner (FDPIC).

17. Additional information for users in the United States

17.1. This section applies to residents of states with comprehensive privacy laws, such as California, Virginia, Colorado, Connecticut, Utah, Texas, Oregon and others.

17.2. In the last 12 months, we have collected the categories of personal information described in Section 4: identifiers, internet or other network activity information, geolocation data, sensory information (camera images) and sensitive personal information (precise geolocation and facial data processed to detect fatigue).

17.3. We do not sell personal information. We do not share it for cross-context behavioural advertising, except for the advertising identifier used for ads in the Waker Maps Basic plan, which you can limit or reset in your phone’s settings. We use sensitive information only to provide the Services requested.

17.4. You have the right to know, access, correct, delete, obtain a portable copy, opt out of the sale or sharing of personal information and of targeted advertising, limit the use of sensitive information and not be discriminated against. We honour Global Privacy Control (GPC) signals where applicable. To exercise these rights, use the e-mail address in Section 12.

17.5. Sources: we collect this information directly from you, automatically through your use of the App, from the Contracting Company to which you are linked and from providers that help us operate the Services.

17.6. Retention periods: each category is retained for the periods set out in Section 10.

17.7. How we handle your request: we need to verify your identity before responding, and we will use the verification data only for that purpose. You may submit the request through an authorised agent, who must provide proof of the authorisation. We respond within the time limits set by the applicable law and, if we need more time, we will explain why. We do not charge for handling requests, except for manifestly unfounded or excessive requests, where the law permits.

17.8. Appeal: if we decline your request, we will explain why. In states that provide for appeals, such as Virginia, Colorado and Connecticut, you may appeal by replying to our e-mail with the subject “Appeal”. If your appeal is denied, you may lodge a complaint with your state’s Attorney General.

18. Additional information for users in Brazil

18.1. You may file a petition with the ANPD or with consumer protection bodies regarding the processing of your data.

18.2. When requesting access or confirmation, please state whether you prefer the response in electronic or printed form and whether you wish to receive an immediate simplified response or a full statement within 15 days, including the origin of the data, the criteria and the purposes, subject to our commercial and industrial secrets.

18.3. When you request correction, erasure, anonymisation or blocking, we will communicate the request to the third parties with whom we have shared the data, unless this proves impossible or involves disproportionate effort.

19. Acceptance record

19.1. When you accept the Terms of Use or this Policy, we record the version and hash of the document, the server date and time, the IP address, the device model and operating system, the App version, the geolocation, a photo from the front camera and the facial landmarks (face mesh), which confirm that a person was in front of the camera.

19.2. These data are used exclusively to evidence acceptance, are kept in a restricted-access area and are retained for the period set out in Section 10. We do not use the facial landmarks to recognise or identify people. Acceptance is only completed once a face is detected; if you deny location access, acceptance is recorded without it, with an indication of the refusal.

20. Changes to this Policy

20.1. We may update this Policy. Each version is given a number and a date. In the event of a material change, the App will display the new version and ask for your acceptance before you continue. Where the change affects processing based on consent, we will ask for your consent again.

21. Definitions

22. Contact

Golden XW Sistemas Inteligentes Ltda. — Rua Haiti, nº 129, Parque das Nações, Santo André/SP, CEP 09280-390, Brazil — suporte@wakerapp.com.br.