Data Processing Agreement

Last updated 8 September 2026

When you use RouteCabin to manage passengers, you decide what is recorded and why. You are the controller. We hold and process it only on your instructions, which makes us your processor. This page sets out the terms that govern that, and forms part of our Terms of Service. If your procurement team needs it signed on paper, email info@routecabin.com and we will send a countersigned copy.

1. What we process, and for whom

Subject matter	Providing the RouteCabin transport management service
Duration	For as long as your account is open, plus the retention period below
Nature and purpose	Storing, organising, displaying, transmitting and deleting records so that you can run your transport operation
Categories of data subject	Passengers (often children), their parents and guardians, your drivers and your staff
Categories of personal data	Names, dates of birth, national identification numbers, home addresses and coordinates, photographs, signatures, phone numbers, institution and class, attendance records, fee slips and payments, and messages sent
Special category data	None is required by the service. Do not enter health or other special category data into free-text fields

2. Our obligations

We process personal data only on your documented instructions. Using the product is such an instruction; so is a written request to us
If a law we are subject to forces us to process it otherwise, we will tell you first unless that law forbids it
Everyone with access is under a duty of confidentiality
We apply the security measures in section 5
We will not engage a new sub-processor without giving you notice and a chance to object
We help you respond to data subjects, and to your own regulator, at no charge
On request we make available what you need to demonstrate our compliance

3. Sub-processors

The complete list. We will give 30 days' notice before adding to it.

Sub-processor	What it does	Location	Basis for transfer
OVH SAS	Hosts the application and database	Dunkirk, France	Inside the EEA — no transfer
FOXAF	Delivers WhatsApp messages you choose to send	Montréal, Canada	European Commission adequacy decision for Canada
IT Vision Private Limited	Our own support and engineering team	Lahore, Pakistan	Standard Contractual Clauses, plus the measures in section 5

Google Analytics is not a sub-processor of your data. It runs on our public website only, behind consent, and never sees a passenger record.

4. Where your data lives

Your database and every file uploaded to it are stored in France, inside the European Union, and are not replicated outside it. The only routine access from outside the EEA is by our support team in Pakistan, which happens when you ask us for help. That access is covered by Standard Contractual Clauses.

5. Security measures

Encryption in transit — the whole service is served over HTTPS
Passwords stored as cryptographic hashes, never in a readable form
Third-party credentials you give us, such as a messaging token, encrypted at rest
Tenant isolation enforced at the database query level, so one customer's account cannot read another's records
Access to production limited to named engineers who need it
Deletion tooling that permanently destroys a record and everything attached to it, for erasure requests

6. Helping you meet your own obligations

If one of your passengers, parents or drivers exercises a right — access, correction, erasure, portability, objection — you can do it yourself inside the app. Where you cannot, ask us and we will carry it out. We will not charge you, and we will not answer them directly, because they are your data subjects, not ours.

We will also give you the information you need for a data protection impact assessment, if you have to carry one out.

7. Breach notification

If we become aware of a personal data breach affecting your data, we will tell you without undue delay and in any case within 48 hours, with what we know: what happened, whose data is affected, the likely consequences and what we are doing about it. You make the call on notifying your regulator and your data subjects, because you are the controller — we will give you everything you need to make it.

8. Return and deletion

When your account closes you may export everything from inside the app, or ask us for a copy. We keep the data for 90 days so that an account closed in error can be restored, then delete it. If you would rather it went immediately, say so and we will do it.

9. Audit

You may audit our compliance with these terms once a year, or after a breach affecting your data, on 30 days' notice. We will answer a written questionnaire at no cost. An on-site audit is at your expense and must not disrupt other customers.

10. Contact

Data protection enquiries: info@routecabin.com
IT Vision Private Limited, Garden Heights, Garden Town, Lahore, Punjab, Pakistan