Draft for review. This notice has not been approved. Highlighted items need confirming by Metutela and counsel before launch. Learners are minors, so this needs particular care.
Privacy notice
Metutela PTDE pilot · Version 2026-10-17 (draft)
Who we are
[Metutela legal entity name and address] ("Metutela", "we") runs the PTDE pilot. Contact us about your data at [privacy contact email].
The pilot runs on technology provided by Cogosense Technology Inc., which operates the FleetSafer app and processes data on our behalf under a written agreement.
Who this covers
The supervising parent or legal guardian who signs up, and the learner they add. Learners are typically 14 to 17. A parent or guardian signs up first and adds their learner; we don't accept sign-ups directly from learners.
What we collect
| Data | From | Why |
|---|---|---|
| Name, email address, mobile number | Parent, at sign-up; learner, in the app | To create accounts and send install links. |
| Your confirmation that you're the learner's parent or guardian and supervising driver | Parent, at sign-up | To record who consented on the learner's behalf. |
| Recruitment source code, if you followed a partner link | The link you used | To know how families found the pilot. |
| Drive data: times, route, distance, speed, braking, acceleration, cornering | The app, while a drive is detected | To log PTDE hours by category and explain how each drive went. |
| Phone handling while the car is moving | The app, while a drive is detected | To show distraction in each session. |
| Your confirmation of each supervised session | Parent, in the app | To build the supervised-driving log. |
| Device information: phone model, operating system, app version | The app | To keep the app working and fix problems. |
We don't read the content of calls or messages. [Confirm whether learner permit details or photos are collected in the pilot, and if so add them here.]
How we use it
- To run the pilot: logging sessions, scoring drives and showing progress to the parent and learner.
- To develop and test Metutela's driving-behaviour model. [Describe this use precisely, including whether pilot data informs future insurance pricing, and get counsel's view on consent for it.]
We don't sell personal data, and we don't use learner data for advertising.
Who can see it
- The supervising parent sees their learner's sessions, categories, progress and scores.
- The learner sees their own sessions and scores.
- Cogosense, which operates the platform for us.
- [Any other recipients, e.g. Texas DPS or an insurer, only if and when that applies.]
Where it's stored
On Amazon Web Services servers in the United States.
How long we keep it
[Retention period for drive data and accounts, during and after the pilot.]
Your choices and rights
You can ask to see, correct or delete your data or your learner's data, or withdraw from the pilot at any time, by contacting [privacy contact email]. Texas residents have rights under the Texas Data Privacy and Security Act. [Counsel to confirm applicable laws and any rights specific to minors' data.]
Changes to this notice
If we change this notice in a way that affects you, we'll tell you in the app or by email before the change takes effect.