1.INTRODUCTION

This privacy policy clarifies how ORBO Ltd (“Orbo”, “we”, “us” or “our”) collects and processes personal information about the User (“you”, “your”) when using our mobile App and website. It also outlines the User's rights and how we use and safeguard their information. Personal information is any information, or a group of related pieces of information, that could be used to reasonably identify the User.

2.PERSONAL INFORMATION WE COLLECT

Through our direct interactions with the User, including the use of automated procedures, we will gather your personal information. Also, we get extra data listed under clause 5 for Driving Instructors only.

3.INFORMATION WE DIRECTLY COLLECT

The User can provide us information by using our mobile App, website or by corresponding with us by email, phone, or another method. Providing personal data in these circumstances includes:

(i) Creating an Account through our mobile App;

(ii) User providing feedback, questions and showing concerns, issues, complaints, opinions, suggestions;

(iii) Requesting to be delivered marketing;

(iv) Contacting us about how to become an Approved Driving Instructor; or

(v) Enter a competition, promotion or survey.

We obtain the following types of data directly from the User:

(i) Identity Data — your first name and last name;

(ii) Contact Data — such as the User’s mobile number and email address;

(iii) Learner Location Data — though this is not mandatory for the use of the Services on this App, when the User turns on location permissions, it allows the User to locate their preferred Meet-Up Point considerably faster;

(iv) Learner Financial Data — for payment purposes, User must provide bank payment card information, including the CVV and expiration date. The expiration date and CVV are solely used to verify the validity of the payment information. Once the payment has been approved, the CVV is not saved;

(v) Technical Data — the App and or website collects personal information from the User, including your login data, internet protocol (IP) address, details about your operating system and platform, as well as information about the devices they use to access the App or website, such as the device ID, device IDFA, and other related technologies;

(vi) Usage Data — such as information on App downloads and information about how the User uses the App and or website;

(vii) Preference Data — including your preferences, feedback and survey responses;

(viii) Marketing Data — including your preferences for how the User wants to receive marketing by us;

(ix) Lesson Ratings — Learners may rate the Instructor’s performance and provide us with additional feedback as so will the Instructor vice versa.

Also, in order for us to verify your identity and establish that the User has the right to access their personal information, we may need to ask the User for particular information (or to exercise any of your other rights). This is a security step to make sure that private information is not given to anyone who shouldn't have access to it. In order to expedite our answer, we might possibly get in touch with the User and ask for more details about your request.

4.INFORMATION WE COLLECT USING AUTOMATED TECHNOLOGIES

We may automatically gather the data listed above while the User uses our App and or website, together with details about your device and browsing tendencies. We may use server logs and other related technologies to gather this personal data.

5.EXTRA INFORMATION WE DIRECTLY COLLECT FROM THE INSTRUCTOR ONLY

As a part of the engagement process with Orbo, Driving Instructors are required to provide us with additional information beyond the general information mentioned further above. Before being engaged, each Driving Instructor must undergo a vetting process that includes a background check conducted by our representatives, either in person, through their App, or by other means. We demand each Driving Instructor to provide us with:

(i) Photo Identity — Instructor must complete an up-to-date profile photo for proof of identity;

(ii) Authorisation — a validation of their driver's licence and other additional forms of identification and confirmation for such Instructors' eligibility to work under the applicable law such as an ADi Badge verification;

(iii) D.O.B and Address — Date of birth and residential address are required for pro government reporting concerns. Such as fraud;

(iv) Car Information — current registration of the Car being used for conducting Driving Lessons through Orbo and agree to the insurance requirements;

(v) Instructor Location Data — this is totally mandatory for the use of our Services on the Orbo ADi App. This is in order for the App to confirm attendance at the Learner's Meet-Up Point, this is how the App will connect both parties as the App can now allow the User to start a Session.

(vi) Instructor Financial Data — for payout purposes, the Approved Driving Instructor may provide their bank account information, this includes the account number and account sort code. Orbo needs this information in order for the Instructor to receive payout for the set lesson Fee(s) from Orbo;

In order to safeguard the privacy and safety of our Users, to uphold our legal responsibilities to them, and to comply with the law, we ask the Instructors to provide this information stated above. Completion and verification of such information will grant the Instructor access to the Service and content within the Orbo ADi App.

6.INFORMATION COLLECTED FROM OTHER SOURCES

We may obtain personal data about a Driving Instructor from third-party sources to complete our background check. This may incdude verification of identity, driving history, criminal background (where legally permitted), and professional qualifications. Such information may be collected from government agencies, licensing authorities, background check providers, or other relevant third parties.

7.HOW WE USE YOUR INFORMATION AND ON WHAT BASIS WE USE IT

We use your personal information in the following ways:

(i) To provide to the Service provider/client in order for Services to be provided/delivered (dependant whether a Learner or an Instructor);

(ii) To handle your queries and requests, as well as to provide support;

(iii) To allow the User to communicate directly with the Learner/Instructor via voice or SMS. We ensure that mobile numbers are kept confidential between the Learner and the Driving Instructor. This information also enables us to resolve disputes and improve the security and safety for the Learner and Instructor;

(iv) To send the User marketing and offers relating to our products and Services via email or push notifications (Unless we are prohibited from doing so by law, or the User has chosen not to receive marketing messages, or another circumstance);

(v) To uphold our legal obligations and to work with regulators and law enforcement;

(vi) To make the marketing messages we send the User to be more relevant and interesting by personalising them;

(vii) To safeguard our rights and those of others;

(viii) To ask the User to take part in surveys. Every time the User responds to one of our surveys, we use the information to better understand your opinions of our Services and tailor them to requirements which are in demand;

(ix) To solicit your participation in polls. To assist us better our product and tailor it to the needs of our Users, we regularly analyse how our Services are used;

(x) For preventing fraud. In order to make sure that Users are using our Services legally, we use automated technology to analyse interactions between our Users and Orbo. Accounts that we suspect of being fraudulent may be suspended.

For us to process your personal information, there must be a legal foundation. In most cases it will be one of the following:

(i) In order to fulfil our duties under the User's contract such as but not limited to, establishing and maintaining your Account, to make sure Services are provided/delivered and to facilitate payments between the Learner and Instructor;

(ii) To uphold our legal obligations, regulations, and audit requirements. Orbo is specifically subject to laws and regulations in Great Britain, where we operate, which call for us to gather and keep track of specific data regarding about the use of the Apps and or website;

(iii) We process your personal information to meet our legitimate interests and those of third parties, which includes understanding how the User uses our Services and developing new Services based on that knowledge. When we use your personal information for our legitimate interests, we take steps to protect your privacy and make sure that your interests and fundamental rights are not compromised.

In some cases, we may be required by law to obtain your consent before collecting and using certain types of personal information. If we ask for your consent, the User has the right to withdraw it at any time by contacting us using the contact details provided at the end of this privacy policy.

We might be obligated by law to gather specific personal data about the User or as a result of any agreements we have with the User. The fulfilment of these obligations may be hindered or delayed if this information is not provided, but we will contact the User if this is the case.

8.HOW YOUR INFORMATION IS SHARED BY US

Under the circumstances outlined below, we may share your personal information with third parties:

Lesson information shared between the Learner and the Instructor when a Booking Request is sent by the Learner to the Instructor, Orbo will provide:

(i) Information to the Learner regarding the Driving Instructor. Including first name, last name and a picture of the Driving Instructor and any other details Orbo considers appropriate; and

(ii) Information to the Driving Instructor regarding the Learner. Including first name, last name and Meet-Up Point, necessary to enabling the Driving Instructor to provide the Driving Lesson Service.

Once the Learner’s Request for a Driving Lesson is confirmed by the Instructor, we may share their personal information with third parties:

(i) Granting the ability to contact the Instructor via SMS, and vice versa.

We may share your personal information with third party service providers and business partners who assist us in carrying out the activities described in this privacy policy. These service providers and partners may include but not limited to companies that provide marketing support, survey tools, technical infrastructure analytics and cloud storage providers. We may also engage professional advisors such as lawyers, bankers, auditors, insurers, or accountants from other companies to assist us.

We may share your personal information with law enforcement agencies, courts, regulators, government authorities, or other third parties. This is in situations where we believe it is necessary to comply with a legal or regulatory requirement, or to protect our rights or the rights of a third party.

If we sell or transfer all or a significant portion of our assets and business to a third party, we may disclose your personal information to that party. We will make reasonable efforts to ensure that the third party uses your personal information in a manner consistent with this privacy policy.

9.SECURITY OF INFORMATION AND STORAGE

We put in place organisational and technical safeguards to guarantee a level of security commensurate with the danger to the personal data we handle. These precautions are meant to maintain the confidentiality and integrity of personal data. To protect the security of the processing, we regularly assess these safeguards.

For as long as we have a close working relationship with the User, we will retain your personal information. We will keep your personal information after our business connection with the User has ended for as long as needed to:

(i) Maintain business records for analysis and/or auditing purposes;

(ii) Comply with any legal restrictions on record retention;

(iii) Defend or file any current or future legal actions;

(iv) Respond to any Service-related complaints.

When it's no longer necessary for these uses, we'll delete your personal data. If there is any data that we cannot completely remove from our systems due to technological limitations, we will put in place the necessary safeguards to stop its further processing or use.

10.USER RIGHTS OVER YOUR PERSONAL INFORMATION

Below are the rights the User has regarding your personal information, subject to local law:

(i)Access and obtain a copy of your personal information;

(ii)Correct or update any incomplete or inaccurate personal information we hold about the User;

(iii) Object to the use of your personal information for certain purposes;

(iv) Request the deletion of your personal information in certain circumstances;

(v) Request the restriction of our use of your personal information in certain circumstances;

(vi) Receive your personal information in a usable electronic format and transmit it to a third party (right to data portability);

(vii) File a complaint with the data protection authority in your jurisdiction regarding our processing of your personal information.

At any time, the User has the right to object to the processing of your personal information for the purposes of advertising and data analysis.

If your personal information changes or if we have inaccurate information about the User, please contact us to update or correct it.

We may contact the User if we need more information to fulfill your requests.

To discuss or exercise your rights, please contact us using the details provided below.

11.CONTACT US

ORBO Ltd is the entity that is responsible for managing the personal information that we collect and process.

If the User has any questions or concerns about how we have used your personal information, please reach out to us using the contact details provided below.

Contact@Orbo.uk

We strive to reach a fair resolution for any privacy-related complaints or concerns the User may have, and we are willing to work with you towards that goal. If the User feels that we have not been able to assist with your complaint or concern, the User has the right to file a complaint with the data protection authority of Great Britain.

12.CHANGES TO THE POLICY

To obtain a copy of this privacy policy, please contact us through the provided details above. Note that we may make changes or updates to this privacy policy at any point.

If we make any changes or updates to this privacy policy, we will post the revised version here (at your notice) and update the "Last Updated" date at the bottom of this policy. Your continued use of our App (and website) following the posting of changes or updates, indicates your acceptance of such changes. If any changes made to this privacy policy significantly affect the nature of the processing of your personal information, or have a considerable impact on the User, then the User will have the right to exercise his/her rights.

We encourage you to review this policy periodically to stay informed about how we are collecting, using, and protecting your personal information.

Last Updated: 15 August 2025

Privacy Policy