Privacy Policy

Last updated: 24/02/2026 · Effective date: 24/02/2026

1. Data Controller

The data controller for personal data collected through this waitlist landing page is the CE.D project, currently in its pre-incorporation phase and operating in Latvia. For all data protection inquiries, please contact: linda.bondare@startschool.org "CE.D", "we", "us", "our"

2. Scope

This Privacy Policy applies only to personal data collected through the waitlist landing page for professional C, CE and D categories truck drivers. The purpose of this page is to allow users to register their interest and receive notification when the recruitment platform becomes available.

3. Personal Data We Collect

When joining the waitlist, we collect: • Name • Country of residence • Email address • Phone number This data is provided directly by the user via the landing page registration form. No identity verification or licence data is collected at this stage.

4. Purpose of Processing

We process the collected personal data for the following purposes: • To notify users when the platform registration becomes available • To manage and maintain the waitlist of interested professional drivers If the user provides separate and explicit consent during the registration process, their contact details may also be used to send occasional marketing communications related to platform features, job opportunities, service updates, and other relevant information about the CE.D platform. This consent will be requested through a dedicated marketing communication checkbox at the time of registration and is entirely optional. Users who do not provide such consent will still be able to use the platform and receive only essential service-related notifications. Consent for marketing communications can be withdrawn at any time through the unsubscribe option included in each communication or by contacting us directly. All waitlist notifications and communications are sent directly by CE.D personnel. We do not use automated third-party marketing platforms for these communications at this stage.

5. Legal Basis

The processing of waitlist data is based on: • Legitimate interest – managing early access registration and notifying users about platform launch • Consent – for optional marketing communications (if the user opts in via the consent checkbox) Users may withdraw marketing consent at any time.

6. Data Storage and Retention

Personal data collected via the waitlist is stored in a secure database hosted within the European Union (EU). The platform infrastructure, including hosting and database services, is provided through EU-based cloud service providers operating under GDPR-compliant data processing agreements. The data is retained for the duration of the waitlist phase until the platform is launched and the initial registration period is completed. After the launch, users will be invited to create a full account on the platform. If a user does not proceed with registration, their waitlist data will be deleted within a reasonable period, unless they have provided additional consent for further communication or processing.

7. Data Sharing

Waitlist personal data is not shared with transport companies or third parties. It is accessed only by authorised CE.D personnel and, where necessary, contracted technical service providers acting under our instructions and confidentiality obligations.

7A. Technical Service Providers (Processors)

We use trusted technical service providers to host and operate the landing page and its underlying infrastructure (such as hosting platforms, database providers, and development repositories). These providers process personal data only on our behalf and in accordance with GDPR-compliant data processing agreements. They do not use the data for their own purposes and do not have independent access beyond what is necessary to provide their services.

8. Cookies and Tracking

The waitlist landing page does not use marketing or tracking cookies. Only strictly necessary technical cookies and local browser storage (used to remember language preference) may be used to ensure proper functionality and user experience.

9. User Rights

Under the GDPR, users have the right to: • Access their personal data • Request correction of inaccurate data • Request deletion of their data • Object to processing based on legitimate interest • Withdraw consent for marketing communications at any time Requests can be submitted to: linda.bondare@startschool.org Users also have the right to lodge a complaint with the Data State Inspectorate of Latvia (Datu valsts inspekcija).

10. Security

We implement appropriate technical and organisational measures to protect personal data, including secure EU-based hosting, access control, and data minimisation practices.

10A. Language Versions

This Privacy Policy may be made available in multiple languages for user convenience. In case of any discrepancies between translations, the English version shall prevail as the legally binding version.

11. Changes to This Policy

This Privacy Policy may be updated to reflect operational or legal changes. Updated versions will be published on this page.