Riteo Privacy Policy

Version 3.2 · In force from 15.10.2026

This is a translation. In case of any discrepancy, the Latvian text prevails.

In short

Riteo is a digital garage with a car's history, documents, deadlines and an AI mechanic. We process data to provide the specific feature you use; for analytics and advertising measurement we ask for a separate choice.

• Photos of the registration certificate and other car documents are received by an AI service provider. They may contain names, addresses and other personal data.
• We store the keeper's and owner's name and the keeper's address shown on the registration certificate on the car card: they are needed for insurance applications, the sale and purchase agreement and the name match check.
• We do not add the plate number, VIN or names to the technical car context we give the AI; such data may nevertheless be visible in your text or photo.
• Files in the personal documents section are not meant to be sent to AI models. If you add a document to an AI chat yourself, its processing is governed by the chat rules.
• Sale listings and the report on a car offered for sale are public. Private documents are not part of that report.
• A shared car history may be kept after one user leaves only on an appropriate basis. Deleting the link to an account does not by itself guarantee anonymity.

1. Controller and contact

The controller is SIA "IT Holding", registration No. 40103880815, VAT No. LV40103880815, Kaivas iela 29 k-1 - 60, Riga, LV-1021, Latvia. Send questions and requests to [email protected]. For all data protection matters the contact point is the controller, at this address.

The sign-in account is maintained by the shared IT Holding platform, which other IT Holding products also use. The controller of Riteo and of the platform account is the same. Deleting Riteo data and closing the whole platform account are two different actions (section 9).

2. Data, purposes and legal bases

"Contract" here means Article 6(1)(b) GDPR and only processing necessary to provide the service you requested. "Consent" means point (a); "legal obligation" point (c); "legitimate interests" point (f), subject to a balancing of interests.

Only the data needed for the chosen feature to work are mandatory. Without authentication we cannot provide an account; without a car identifier we cannot request registry data; without a document we cannot read it. You may choose not to use the personal documents, voice, location or listing features. Refusing analytics does not limit the core service.

Location

Riteo does not track your location in the background. The app asks for the device location only when you tap "Near me" in the list of dealers and services. We send the approximate coordinates to our server once, to sort that list by distance; we do not keep them after the answer. If you do not grant permission, the list is sorted by name.

Legitimate interests

These include preventing unauthorised access and fraud, handling complaints, defending claims and a lawful car manager's interest in a reliable shared history. We assess necessity, less restrictive options and the impact on people. Objections are considered individually; a refusal is not decided in advance.

3. Sources and other persons' data

We receive data from you, from the sign-in service you chose, from a lawful card manager or inviter, from the registry and from the vehicle data catalogue used. In Latvia the registry source is CSDD; for a query we send the necessary plate number or VIN. RDW and DMR are not activated sources. If we add another source, we will update this information before the processing concerned.

In the list of official dealers and services we show company contact details (name, address, phone, opening hours) from public sources. These are company data, not users' personal data.

A document may contain the data of another owner, keeper or representative. Upload only what you have a legal basis for and what the feature needs. Riteo's duty to inform the data subject is not replaced by a user's promise. Where we obtain data indirectly, we provide the information required by Article 14 GDPR within the set time — as a rule no later than within one month and, where relevant, earlier at the first communication or disclosure — unless a specific, documented exception applies.

You pass on the driver invitation link yourself; we do not use the invitation e-mail address for advertising. On the invitation page, before accepting access, the invited person sees a link to this policy.

4. AI, document reading and voice

The initial reading of the registration certificate is done on the device by Google ML Kit. This does not mean the photo stays only on the device: for server-side reading the photo is sent to OpenAI. We also use OpenAI to read images of policies, inspections, invoices, receipts, the odometer and tyres, for the AI mechanic, translation and support. We use Anthropic for maintenance recommendations. Specific model versions may change without changing the purpose of processing.

For photos and texts the provider receives all submitted content, including the personal data visible in it. We do not add the name, VIN or plate number to the technical car context for the AI mechanic and the service plan; this is not a promise that your message cannot contain them. To generate a car illustration we use the make, model, generation and body type, not a personal document.

Your phone reads the driving licence (Google ML Kit on the device); its photo and the recognised text are sent neither to us nor to AI providers — only the expiry date, the categories and the year (or date) you started driving reach your account. If you lose the phone, the photo goes with it; those details stay in your account. We do not automatically send other files from the personal documents section for AI reading, but our file processor stores them. Riteo does not keep passports or ID cards — do not add them to the AI chat.

Under the applicable API agreements, submitted content is not intended to be used to train the providers' general models. This does not mean zero retention: we do not use a zero data retention mode, and the provider may keep requests, security records or feature state for a limited time under its data processing agreement.

Voice. In the iOS and Android app, speech is turned into text by the phone's system speech recogniser (Apple or Google — on the device or through the operating system's service). The web version uses the browser's speech recognition; for example, Chrome sends the audio to Google's speech recognition service. Browser recognition is not automatically local-only processing. Voice recordings in the AI mechanic chat are stored by Riteo and are not sent to AI models; the model receives the transcribed text.

You check the read fields before confirming them. Riteo does not make decisions about you based solely on automated processing with legal or similarly significant effects within the meaning of Article 22 GDPR. You can ask for automated content filters and restrictions to be reviewed by a human. Mileage inconsistencies and price guides are not an individual fraud or creditworthiness assessment.

5. Analytics, advertising measurement and consent

A hash is not anonymous data if it can be linked to a person. We do not activate analytics or the sending of Meta events before the relevant consent. A refusal is not a reason to keep the content of a rejected analytics event for later sending. Evidence of the consent choice and necessary security records are separate processing.

In the choice you can accept all, refuse all or choose by category. You can change your choice in Profile → Settings → Privacy settings or by writing to us. Withdrawal stops the relevant further processing; it does not affect the lawfulness of earlier processing. Deletion of data is assessed separately.

We use necessary session, authentication and security technologies to provide the service. Optional analytics cookies, local storage or SDK identifiers are used only after the applicable consent.

6. Recipients and international transfers

We impose contractual data protection obligations on processors. Authentication and advertising providers may, for certain operations, be independent or joint controllers; the role is determined by the specific integration and contract, not merely by the name in this document. We do not use the EU data residency option of the OpenAI and Anthropic services.

Data may also be received by a lawful co-user, a conversation partner or a viewer of a public listing, as described in section 8, and by authorities or legal advisers where necessary to comply with the law or to resolve legal claims.

A transfer outside the EEA is allowed only on an applicable basis under Chapter V GDPR. The EU–US Data Privacy Framework is used only where it applies to the specific certified recipient entity and data; in other appropriate cases EU standard contractual clauses and the necessary supplementary measures are used. Storing data in the EU does not in itself rule out access from third countries. You can ask about the applicable safeguard and a copy of it at [email protected].

7. Retention periods

We keep data no longer than needed for the specific purpose. The table separates the source document from confirmed card data. An earlier justified erasure request may shorten the period; a specific legal dispute or obligation may require limited longer retention.

8. Who sees your data

Shared car. Depending on their role, co-users see the shared mileage, inspection and tyre records. In the current model a policy is seen by the person who added it and by the car's drivers; expenses entered by a driver are seen by the card manager. An invitation or code is not a general permission to receive all private documents.

Messages. The conversation partner sees messages and attachments. A notification text may contain the message content, which may appear on the lock screen depending on device settings.

Listing. Photos, price, equipment, the available mileage history and the price guide are public. The seller page shows the first name, last-name initial and the cars for sale. Reviews of business sellers are public.

Report by plate number. Only for a car offered for sale, the public report shows make, model, year, whether it has a manager in Riteo, the date since the car has been in Riteo, the latest mileage and its date, the number of records, a mileage decrease indicator, the inspection deadline, sale status and price. The report contains no name, VIN or private documents. When the car is taken off sale, Riteo no longer shows this report publicly.

A plate number, VIN and vehicle history may in certain circumstances be personal data. A public listing does not mean waiving data protection rights.

9. Deletion and card transfer

The profile offers two options:

• "Delete Riteo data only" deletes your Riteo data and keeps the IT Holding platform account, so you can continue to use other IT Holding products;
• "Delete account" deletes your Riteo data and closes the shared IT Holding platform account, which other IT Holding products also use.

Before you confirm, the app explains what each option affects. If deletion processing fails, we tell you and provide a way to contact us; the failure does not cancel the request.

We delete your links to cards, the keeper's and owner's name and address stored on the card, personal documents, private policies, invoices, expenses and attachments, photos, the AI chat, reminders, saved searches, invitations, notifications and tokens, and your analytics data, unless there is a separate lawful basis for keeping them.

Your conversation partner immediately sees the mark "message deleted" instead of your deleted messages. We keep the message texts under restricted access for 100 days for fraud investigation or a deal dispute, then erase them. Article 17(3)(e) GDPR is not an automatic permission to keep all content of a deleted account.

If there is no other lawful manager or recipient, we delete the card together with its history. If only watchers or drivers remain on the car, we delete its history 3 months after the last manager left. If there is another lawful manager or recipient, the shared mileage and inspection history stays with the car, which we assess as necessary for their legitimate interests. We separate the former user's personal documents and unnecessary identifying links from the shared history. We do not claim that data become anonymous merely because the link is deleted. We keep only the latest register data (inspection and OCTA deadlines) that the remaining users see.

When a card is transferred by code, the recipient receives the mileage, inspection records and tyre data. The seller's private expenses, policies, invoices, documents, chats and photos do not pass to the recipient and are deleted. Before confirming, the app warns about this and lets you download a copy (export) of your Riteo data. This is not a transfer of legal ownership.

Deletion also covers personal data available to processors to the applicable extent. Where identified data must be deleted in Firebase or another system, waiting for the two-month period to expire does not by itself replace handling the request.

10. Your rights and how requests are handled

• To receive information and a copy of your personal data.
• To rectify inaccurate data and complete incomplete records.
• To request erasure and restriction of processing where the applicable conditions are met.
• To object to processing based on legitimate interests; for direct marketing an objection is honoured without balancing interests.
• To withdraw consent as easily as it was given, without affecting the lawfulness of earlier processing.
• To receive portable data in a structured, commonly used and machine-readable format where portability under Article 20 GDPR applies and, where technically feasible, to ask for it to be sent to another controller.

The JSON export available in the profile may not cover everything. Request the missing data — including personal documents, mileage, tyres, messages, reviews and personal data in analytics — at [email protected]. A limitation of the export does not limit your statutory rights; we also protect the rights of others.

We respond without undue delay and as a rule within one month of receiving the request. For complex or numerous requests the period may be extended by two further months, with the reason given within the first month. If there are reasonable doubts about identity, we ask for proportionate additional information. We do not automatically require a passport copy for every request.

Requests are as a rule free of charge. A refusal, or a fee permitted by law for a manifestly unfounded or excessive request, is justified and the complaint options are explained.

You can lodge a complaint with the Data State Inspectorate (Datu valsts inspekcija), Elijas iela 17, Riga, LV-1050, or another competent EEA supervisory authority. This does not limit the right to go to court.

11. Security

We apply technical and organisational measures appropriate to the risk: access restriction, separated systems, protected file storage and management of access keys. Staff access data only for work needs. We do not include unnecessary document content or external service secret keys in logs.

We keep server backups for up to 1 year with restricted access. When the system is restored from a backup, deletions are applied again so that already deleted data do not regain everyday availability. We report personal data breaches to the authority and the affected persons where GDPR requires it. No system can guarantee absolute security.

12. Children and changes

Riteo is not intended for persons under 18. If we find an inappropriate registration, we assess deleting the data and the necessary protective measures.

We inform you of material changes before the processing concerned starts. If new consent is needed, publishing the policy or continued use does not replace it. We keep previous versions; the consent evidence records the choice made and the document version.

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