This policy (together with our policies on ‘How we process your data’, ‘Cookies and other technologies’ and ‘To whom we transfer your data’) sets out:
Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
For the purposes of the data protection laws and directives applicable to the European Union, (the “Data Protection Law“), the data controllers are:
Information we collect about you
We will collect and process the following personal data from you:
This is information about you that you give us directly when you interact with us. This includes your profile information, login details, and other details required to create your register with us.
This is information about you that you give us by filling in forms on the Site or App or by corresponding with us by phone, e-mail or otherwise. It includes information you provide when you register to use the Site or App, subscribe to our service, search for a product, place an order on the Site or App, participate in discussion boards or other social media functions on or via the Site or App, enter a competition, promotion or survey, submit a query, and when you report a problem with the Site or App.
The information you give us may include your name (including account username), address (including the city you live in), e-mail address and phone number, financial and credit card information, personal description (including age and gender), photograph, login and password details. It may also include certain personal details of your emergency contacts that you add to your account, and whether you have a connection with others whose personal data we may collect or hold, for example family members and friends. We may also access contacts stored on your device in order for you to add them to your favourites or emergency contacts. Please note that we do not import or sync your contact with the Site/App.
You may also choose to share details of your membership in any loyalty programs with which we are partnered, including the date and expiry details of the membership, membership number and points/rewards accrued. We may also collect information from you to undertake market research and studies, conduct data analysis, determine and customize product or service offerings, to improve the products or Services or to make any other benefits/products/ services available to you.
We will automatically collect information from you each time you visit the Site and/or use our App. This includes technical information, information about your visit, and your location data.
We collect information about how you use our Services, such as the types of content you view or engage with; the features you use or click on; the actions you take; the people or accounts you interact with; the content you post on the Services (including using device features such as cameras, microphones, and text entered when using the Services) where applicable; using and have last used our Services; and the time, frequency and duration of your activities.
Technical information may include the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, browser type, referring / exit pages and URLs, number of clicks, domain names, landing pages, pages viewed and other such information.
Information about your visit may include the full Uniform Resource Locators (URL), clickstream to, through and from our Site (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call our customer service number or social media handle used to connect with our customer service team. It may also include reference numbers used when you book a service through the Site or the App, and details of what, how, when and where you have engaged in services which we provide or services procured or booked using our services. Where the Services allow you to call or text other users using the Services, the information may also include call and text information, including the date, time and duration of the calls and texts.
Location data – we collect information through the Site/App as to your real time location to provide location services where requested or agreed to by you in order to deliver content and services that are dependent on knowing where you are, such as allowing passengers to find drivers, allowing drivers to find passengers for pickup and allowing the App to calculate the fare applicable to your journeys. Please note that we only collect your live location on the Site/App if you specify in your setting that you would like us to “always collect” your location. If you have not specified this, we not collect your live location unless you are accessing the Site/App or availing our services. This information is collected in combination with an identifier associated with your device to enable us to recognise your mobile browser or device when you return to the Site/App. You may also feed in your location manually in the Site/App. You may turn off location access using your device or not provide us your location manually, however, please note that without the ability to collect your location we will not be able to provide you our services. For example, while riders may be able to manually enter their location information, they will not be able to use certain aspects of the Services such as sharing live locations with their emergency contacts, friends or family. However, please note that collection of location information is required for drivers. Location information is collected from every driver, even if the corresponding rider’s location sharing is turned off for that trip.
Device information i.e. the devices you use (mobile phones, computers, tablets, etc.) to access our services such as the hardware models, operation system information, hardware and software information and version, file names, language preferences, IP address cookie information, advertising identifiers, plugins, browser version, device settings, and mobile network information. We may also collect information about operations or actions performed on the device, such as mouse movements and whether a window is in the foreground or background. We may recognise your devices to provide you with personalised experiences and advertising across the services you use. Please see our policy on ‘Cookies and other technologies’ for more information on how we use device information.
We will also collect certain transactional information from you regarding your trips, including the amount or fare charged (including taxes), the date and time of the rides, details of referral codes or vouchers used, the distance travelled and route taken, ratings and compliments, and details where you have contacted the driver or rider or our customer care personnel (such as call recordings, feedback over the App or Site, text messages or email, or over any other medium in which we may collect customer care information such as your complaints and requests). This information in generated about you by your use of the Services. This information is required for our record maintenance purposes, and for financial, tax, administrative and audit purposes. We may also require this information to provide better customer support to you, to detect and mitigate instances of fraud, and for any R&D purposes. We will also contact you regarding changes to our terms of service or privacy policies.
We may enable you to communicate with drivers or riders through our App or Site, through which we will collect information regarding the communications made, requests or complaints filed, the contents of any text messages, calls, files, and other information that are disclosed by you through these communication media, and the data and time of the communications. We will not share any personal information of your or any other party through such communication media, unless you choose to do so voluntarily. We may also use this data for better customer support services, for analytics, feedback on our Services, or for safety purposes.
We may collect demographic data about you through surveys and feedbacks. You many opt to provide this information to us, and we will use this to provide better or new Services to you. We may also receive demographic data from our third-party partners regarding you, which we may combine with the data you provide to us.
We will also collect information regarding complaints or requests you place with our Data Protection Officer, and may also receive details regarding such complaints or requests from third parties you may appoint or regulatory, judicial or administrative authorities.
Other than your locations and device information and transactional data, we do not link this automatically-collected data to personally identifiable information.
This is information we receive about you:
Depending on the nature of your dealings with us or the services which we provide to you or which you may obtain or make available to others using our services, we may collect other types of personal data from third parties, including:
You generally have the option of not identifying yourself or of using a pseudonym when dealing with us, but not where this is impractical (for example when you transact online with us or you apply to provide transport-related services) or where the law or a court order provides otherwise.
In this case we will have informed you when we collected that data if we intend to share your data internally and combine it with data collected on this site. We will also have told you for what purpose we will share and combine your data.
We are working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, and search information providers). We will notify you when we receive information about you from them and the purposes for which we intend to use that information.
We may use the aforementioned data as-is or in combination with other data that you provide us or is derived about you.
How we use your information
You can see a full list of the types of data we process, the purpose for which we process it, and the lawful basis on which it is processed here.
Please note that we use the information you provide to us for automated decision making and profiling in order to effectively provide you our services.
We use information held about you in the following ways:
We will use this information to:
We will use this information in our legitimate interests, where we have considered these are not overridden by your rights:
We will combine this information with information you give to us and information we collect about you in our legitimate interests (where we have considered that these are not overridden by your rights). We will use this information and the combined information for the purposes set out above (depending on the types of information we receive).
Our promotional updates and communications
We will share promotional updates and communications with your consent or, where applicable, in our legitimate interest. Where permitted in our legitimate interest, we will use your personal information for marketing analysis and to provide you with promotional updates and communications by email, telephone, text messages, in-application messages and/or push messages about our products and/or services. We may also share information with third-party social media and other partner platforms in order to provide you with promotional update communications.
The types of communications we may sent includes information regarding Coolrides ’s services, features, research and development efforts, surveys, studies, news, updates, and events. We may also personalise the communications we send based on your use of the App/ Website, such as your frequently visited locations to provide you with offers, your existing user preferences and settings, and feedback you may have provided to us.
You can object to further marketing at any time in your profile settings or by selecting the “unsubscribe” link at the end of our marketing and promotional update communications to you.
Who we give your information to
We may give your information to:
Where we store your information
We may transfer your personal information outside the EEA:
We may transfer your personal information to the following countries outside the EEA such as India, Singapore, Indonesia, Ireland, the Philippines and the United States of America.
The Website/App is intended for use only by persons who are at least 18 years of age. By using the Website/App, you confirm to us that you meet this requirement.
How we protect your information
All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted using SSL technology. Where we have given you (or where you have chosen) a password which enables you to access certain parts of the Services, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to the services; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
Our Site may, from time to time, contain links to external sites. We are not responsible for the privacy policies or the content of such sites.
How long we keep your information
We retain personal data for (i) as long as you have an account with us in order to meet our contractual obligations to you, and (ii) for six years after that to identify any issues and resolve any legal proceedings. We may retain information for any other legal or regulatory requirement. During the period of retention, whether or not you use the App/ Website or access the Services, we may use your information for purposes of taxation, litigation or resolution of any claims, insurance, safety and security, fraud management or internal research. We may also retain aggregate or anonymised information beyond this time for research purposes and to help us develop and improve our services. You cannot be identified from aggregate or anonymised information retained or used for these purposes.
Subject to applicable law, you have the right under certain circumstances:
You may opt out at any time from allowing further access by us to your location in your device settings. You can also stop all information collection by un-installing the App. You may use the standard un-install processes as may be available for your mobile device.
Your right to withdraw consent: Where the processing of your personal information by us is based on consent, you have the right to withdraw that consent without detriment at any time by contacting us on the details provided below. You can also change your marketing preferences at any time as described in the section ‘Our promotional updates and communications‘ above. Please note that withdrawing of consent has no impact on earlier processing of your personal data on such basis and does not prevent us from invoking another available legal basis for the processing of such personal data.
Right to lodge a complaint: If your request or concern is not satisfactorily resolved by us, you may approach your local data protection authority. The ‘Information Commissioner’ is the supervisory authority in the UK and can provide further information about your rights and our obligations in relation to your personal data, as well as deal with any complaints that you have about our processing of your personal data.
Riders may use the self-serve function on the Website/App in order to exercise the above rights. Drivers may exercise these rights by contacting us at email@example.com. We may reach out to you to verify your identity or fulfil any other verification requirements before processing a request.
Please note that we may be unable to delete your information if there is a pending claim or dispute relating to your account, including any outstanding payments.
Changes to this policy
This policy was last updated on 22nd August 2020.
COOL CARS UK Private Limited
23a The Precinct, London Road, Waterlooville, Hampshire, United Kingdom, PO7 7DT
Email address: firstname.lastname@example.org
To whom we transfer your data
We may share or disclose your personal data to the following:
If you require any further information on disclosure of your personal data, please write to us at email@example.com
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