As used in this Notice:
- “customer” means an individual who (a) has contacted us through any means to find out more about any goods or services we provide, or (b) may, or has, entered into a contract with us for the supply of any goods or services by us.
“personal data” means data, whether true or not, about a customer who can be identified: (a) from that data; or (b) from that data and other information to which we have or are likely to have access.
- Depending on the nature of your interaction with us, some examples of personal data which we may collect from you include name, email address and telephone number.
Other terms used in this Notice shall have the meanings given to them in the PDPA (where the context so permits).
Data collections and uses
A. The data we collect:
• provided by users to our apps, such as during account creation
• created during use of our services, such as location, app usage, and device data
• from other sources, such as other users or account owners, business partners, vendors, insurance and financial solution providers, and governmental authorities.
The following personal data is collected by or on behalf of our app:
1. Data provided by users. This includes:
• User profile: We collect data when users create or update their app accounts. This may include their name, email, phone number, login name and password, address, profile picture, payment or banking information (including related payment verification information)
We may use the photos submitted by users to verify their identities, such as through facial verification technologies. For more information, please see the section titled “How we use personal data.”
Approximate location (Physical user or device location within an area greater than or equal to 3 square kilometers. For example, the city a user is in, or location provided by the ACCESS_COARSE_LOCATION Android permission.)
Precise location (Physical user or device location within an area less than 3 square kilometers. For example, location provided by the ACCESS_FINE_LOCATION Android permission.)
Sms (A user's text messages, including the sender, recipients, and the content of the message)
• We verify the identities of Customers, or of Delivery/Service recipients who request alcohol delivery, including by collecting photographs of their government-issued identification.
• Demographic data: We may collect demographic data about users, including through user surveys. In some countries, we may also receive demographic data about users from third parties.
We may also infer demographic data from other data collected from users. For example, where necessary to enable features that allow women to provide or receive services from other women, we may infer gender using their first name. In such cases, we enable users to change their gender if necessary via in-app settings.
• User content: We collect the data submitted by users when they contact our customer support (including via videoconferencing tools), provide ratings or compliments for other users, vendors or merchants, or otherwise contact Us. This may include feedback, photographs or other recordings collected by users, including audio or video recordings (such as from dashcams) submitted by users in connection with customer support. This also includes metadata relating to the method you use to communicate with US through the apps.
• Files and docs
Files and docs (A user's files or documents, or any information about a user's files or documents. For example, file names.)
• Device or other IDs
Device or other IDs (Identifiers that relate to an individual device)
• Financial info
User payment info -Information about a user’s financial accounts such as credit card number. Purchase history
Information about purchases or transactions a user has made.Credit score
Information about a user’s credit score.Other financial info
Any other financial information such as user salary or debts
• Voice or sound recordings for product searching
• Health and fitness
Information about a user's health, user's fitness, such as medical records or symptoms.
• Other in-app messages
A user’s text messages including the sender, recipients, and the content of the message.
1. Data created during use of our services. This includes:
• Location data (driver, service provider and delivery person): We collect Drivers/Service Providers’ and Delivery/Service persons’ precise or approximate location data, including to enable services and deliveries, to enable services/delivery tracking and safety features, to prevent and detect fraud, and to satisfy legal requirements. The app collects this data when our app is running in the foreground (app open and on-screen) or background (app open but not on-screen) of their mobile device.
• Location data (Customers and Delivery/Service recipients). We collect Customers’ and Delivery/Service recipients’ precise or approximate location data to enable and enhance use of our apps, including to improve pick-ups, facilitate deliveries, enable safety features, and prevent and detect fraud.
We collect such data from users’ mobile devices if they enable us to do so. (See “Choice and transparency” below for information on how Customers and Delivery/Service recipients can enable location data collection). Our apps collects such data from the time a service or delivery is requested until it is finished (and may indicate such collection via an icon or notification on your mobile device depending on your device’s operating system), and any time the app is running in the foreground (app open and on-screen) of their mobile device.
Customers and Delivery/Service recipients may use the apps without enabling to collect precise location data from their mobile devices. However, this may affect features in the apps. For example, a user who has not enabled location data collection will have to manually enter their pick-up address. In addition, the location data collected from a driver during a trip will be linked to the rider’s account, even if the rider has not enabled location data to be collected from their device, including for purposes of receipt generation, customer support, fraud detection, insurance, and litigation.
• Transaction information: We collect transaction information related to the use of our services, including the type of services requested or provided, order details, payment transaction information (such as a vendor’s or merchant's name and location and amount of transaction), delivery information, date and time the service was provided, amount charged, distance traveled, and payment method. Additionally, if someone uses your promotion code, we may associate your name with that person.
• Usage data: We collect data about how users interact with our services. This includes data such as access dates and times, app features or pages viewed, app crashes and other system activity, and type of browser. We may also collect data regarding the third-party sites or services used before interacting with our services, which we use for marketing. (Please see "How We Use Data" below for more information on how we market our services to users).
In some cases, we collect this data through cookies, pixels, tags, and similar tracking technologies that create and maintain unique identifiers.
• Device data: We may collect data about the devices used to access our services, including the hardware models, device IP address or other unique device identifiers, operating systems and versions, software, preferred languages, advertising identifiers, device motion data, and mobile network data.
• Communications data: We enable users to communicate with each other through our mobile apps and websites. For example, we enable Drivers/Service Providers and Customers, and Delivery/Service persons and Delivery/Service recipients, to call, text, or send other files to each other (generally without disclosing their telephone numbers to each other). To provide this service, We receives some data regarding the calls, texts, or other communications, including the date and time of the communications and the content of the communications. We may also use this data for customer support services (including to resolve disputes between users), for safety and security purposes, to improve our services and features, and for analytics.
2. Data from other sources. These include:
• Users participating in our referral programs. For example, when a user refers to another person, we receive the referred person’s personal data from that user.
• users or others providing information in connection with claims or disputes.
• Our business partners through which users create or access their account, such as payment providers, social media services, or apps or websites that use Our APIs.
• Our business partners in connection with debit or credit cards issued by a financial institution in partnership with Us to the extent disclosed in the terms and conditions for the card.
• vendors who help us verify users’ identity, background information, and eligibility to work, or who screen users in connection with sanctions, anti-money laundering, or know-your-customer requirements
• publicly available sources
• marketing service providers or data resellers whose data uses for marketing or research
• law enforcement officials, public health officials, and other government authorities
We may combine the data collected from these sources with other data in its possession.
B. How we use personal data
We uses personal data to enable reliable and convenient transportation, delivery, and other products and services. We also use such data:
• to enhance the safety and security of our users and services
• for customer support
• for research and development
• to enable communications between users
• to send marketing and non-marketing communications to users
• in connection with legal proceedings
We does not sell or share user personal data with third parties for their direct marketing, except with users’ consent.
We use personal data we collect:
1. To provide our services. We uses data to provide, personalize, maintain, and improve our services.
This includes using data to:
• create/update accounts
• enable transportation and delivery services (such as using location data to facilitate a pick up or delivery), features that involve data sharing (such as fare splitting, ETA sharing, and ratings and compliments), and accessibility features to facilitate use of our services by those with disabilities
• process payments
• track and share the progress of services or deliveries
• create travel itineraries and offer related services, such as services to the airport, rental car reservations, or food deliveries.
• personalize users’ accounts. We may, for example, present an user with personalized recommendations based on their prior orders. Please see the section of this notice titled “Choice and transparency” to learn how to object to this use of personal data.
• facilitate insurance, vehicle, invoicing, or financing solutions
• perform necessary operations to maintain our services, including to troubleshoot software bugs and operational problems; to conduct data analysis, testing, and research; and to monitor and analyze usage and activity trends.
2. Safety and security. We use personal data to help maintain the safety, security, and integrity of our services and users. This includes:
• verifying users' identity and eligibility to provide transportation or deliveries, including through reviews of background checks, where permitted by law, to help prevent use of our services by unsafe Drivers/Service Providers and/or Customers.
In certain regions, this includes Real-Time ID Check feature, which prompts Drivers/Service Providers and Delivery/Service persons to share a selfie before going online to help ensure that the driver or delivery person using the app matches the account we have on file. Where permitted by law, this also includes performing facial verification of photographs submitted by users, or collected from public databases, to prevent identity-borrowing or to verify users’ identities.
• using device, location, user profile, usage, and other data to prevent, detect, and combat fraud. This includes identifying fraudulent accounts or uses of our services, preventing use of our services by unauthorized Drivers/Service Providers or Delivery/Service persons, verifying user identities in connection with certain payment methods, and preventing and combating unauthorized access to users’ accounts.
• using user ratings, reported incidents, and other feedback to encourage compliance with our Community Guidelines and as grounds for deactivating users with low ratings or who otherwise violated such guidelines in certain countries.
• sharing information regarding serious driver or delivery person safety incidents or compliance with local regulations with third parties, including other companies who enable users to request or provide rides or delivery services, or intermediaries who collect and report such information for multiple companies, to prevent Drivers/Service Providers or Delivery/Service persons who may pose a safety risk to the platform or its users from using Tranzit Technologies’s or those other companies’ services. We may also share with third parties, including those affected by such incidents, whether the incidents result in account deactivation.
• using ratings, usage and other data to prevent matching of Customers and Drivers/Service Providers for whom there is higher risk of conflict (for instance, because one user previously gave the other a one-star rating).
3. Customer support. We uses the information we collect (which may include call recordings) to provide customer support, including to investigate and address user concerns and to monitor and improve our customer support responses and processes.
4. Research and development. We may use personal data for testing, research, analysis, product development, and machine learning to improve the user experience. This helps us make our services more convenient and easy-to-use, enhance the safety and security of our services, and develop new services and features.
5. Enabling communications between users. For example, a driver may message or call a customer to confirm a pickup location, a customer may contact a driver/service provider to retrieve a lost item, or a vendor or delivery person may call a delivery recipient with information about their order.
6. Marketing. We may use personal data to market our services to our users. This includes sending users communications about our services, features, promotions, sweepstakes, studies, surveys, news, updates, and events. We may do so through various methods, including email, text messages, push notifications, in app communications and ads, and ads on third party platforms.
We may also inform users about products and services offered by Our partners. For example, we may provide recommendations, promotions, or ads for our partners based on users’ past delivery orders. Although we inform users about products and services offered by Our partners, we do not sell users’ personal data to, or share it with, such partners or others for purposes of their own direct marketing or advertising, except with users’ consent.
We may use the data we collect, including in combination with advertising partners’ data, to personalize and improve the marketing communications (including ads) that we send on and off the apps and websites, including based on user location, use of Our services, and user preferences and settings. For example, we share user data (such as hashed email address, usage information, and device or user identifiers) with Facebook and TikTok to personalize and improve our ads for Our services.
For information about how to opt out of certain marketing communications (including ads) from Us and its advertising partners, please see the section titled “Marketing choices.”
We may also send users communications regarding elections, ballots, referenda, and other political and notice processes that relate to our services. For example, We notified some users by email of ballot measures or pending legislation relating to Our services in those users’ areas.
We performs the above activities on the grounds that they are necessary for purposes of legitimate interests in informing users about Our services and features or those offered by Our partners, or on the basis of user consent. See the sections titled “Choice and transparency” and “Marketing choices” for information on your choices regarding Tranzit Technologies’s use of your data for marketing.
7. Non-marketing communications. We may use personal data to generate and provide users with receipts; inform them of changes to our terms, services, or policies; or send other communications that aren’t for the purpose of marketing the services or products.
8. Legal proceedings and requirements. We may use personal data to investigate or address claims or disputes relating to use of our services, to satisfy requirements under applicable laws, regulations, or operating licenses or agreements, or pursuant to legal process or governmental request, including from law enforcement.
9. Automated decision-making
We use personal data to make automated decisions relating to use of our services. This includes:
• enabling dynamic pricing, in which the price of a service, or the delivery fee for Tranzit Technologies orders, is determined based on constantly varying factors such as the estimated time and distance, the predicted route, estimated traffic, and the number of Customers and Drivers/Service Providers using at a given moment.
• matching available Drivers/Service Providers and Delivery/Service persons to users requesting services. Users can be matched based on availability, proximity, and other factors such as likelihood to accept a trip based on their past behavior or preferences.
• determining user ratings, and deactivating users with low ratings. In the European Union or where otherwise required by law, such deactivation occurs only after human review and/or the possibility to appeal. Please also see the section below titled “Ratings look-up” for further information.
• flagging users who are identified as having engaged in fraud, unsafe activity, or other activities that may harm Tranzit Technologies, its users, and others. In some cases, such as when a user is determined to be abusing Tranzit Technologies’s referral program or has submitted fraudulent documents, such behavior may result in automatic deactivation, or in the European Union or where otherwise required by law, deactivation after human review.
• using driver location information, and communications between Customers and Drivers/Service Providers, to identify cancellation fees earned or induced through fraud. For example, if we determine by using such information that a driver is delaying a delivery pickup in order to induce a cancellation, we will not charge the customer a cancellation fee and will adjust the amounts paid to the driver/service provider to omit such a fee. To object to such an adjustment, please contact Our customer support.
• Using driver/service provider data (such as location, rating and gender) and customer data (such as rating, origin and destination) to help avoid pairings of users that may result in increased risk of conflict.
To object to a deactivation resulting from these processes, please contact Our customer support.
C. Cookies and third-party technologies
remembering user preferences and settings
determining the popularity of content
delivering and measuring the effectiveness of advertising campaigns
analyzing site traffic and trends, and generally understanding the online behaviors and interests of people who interact with our services
D. Data sharing and disclosure
Some of Our app services and features require that we share data with other users or at a user’s request. We may also share such data with our affiliates, subsidiaries, and partners, for legal reasons or in connection with claims or disputes.
We may share data:
1. With other users
This includes sharing:
riders’ first name, rating, and pickup and/or dropoff locations with drivers.
riders’ first name with other riders in a carpool trip. Riders in carpool trips may also see the dropoff location of the other riders.
order recipients’ first name, delivery address, and order information with the restaurant or merchant and, for order deliveries, with the delivery person. We may also share ratings and feedback, or other information to the extent required by law, with the restaurant or merchant and, for order deliveries, the delivery person.
for drivers and delivery persons, we may share data with the rider(s), order recipient(s) and restaurants or merchants, including name and photo; vehicle make, model, color, license plate, and vehicle photo; location (before and during trip); average rating provided by users; total number of trips; period of time since they signed up to be a driver or delivery person; contact information; and driver or delivery person profile, including compliments and other feedback submitted by past users.
We also provide riders and order recipients with receipts containing information such as a breakdown of amounts charged, driver or delivery person first name, photo, and route map. We also include other information on those receipts if required by law.
for those who participate in our referral program, we share certain data of referred users, such as trip count, with the user who referred them, to the extent relevant to determining the referral bonus.
2. At the user’s request
This includes sharing data with:
Other people at the user’s request. For example, we share a user’s ETA and location with a friend when requested by that user, or a user’s trip information when they split a fare with a friend.
Our business partners. For example, if a user requests a service through a partnership or promotional offering made by a third party, We may share certain data with those third parties. This may include, for example, other services, platforms, apps, or websites that integrate with our APIs; vehicle suppliers or services; those with an API or service with which we integrate; or restaurants, merchants or other business partners and their users in connection with promotions, contests, or specialized services.
Emergency services: We offer features that enable users to share their data with police, fire, and ambulance services in the event of an emergency or after certain incidents. For more information, please see the sections below titled “Choice and Transparency” and “Emergency Data Sharing”.
3. With the general public
Questions or comments from users submitted through public forums such as Our blogs and social media pages may be viewable by the public, including any data included in the questions or comments submitted by a user.
4. With the App account owner
If a user receives services through an account owned by another party, we may share their trip or order information, including location data, with the owner of that account. This occurs, for example, when:
a rider uses their employer’s for Business profile, such as when they take trips arranged through Our App Central
a driver or delivery person uses an account owned by or associated with Us partner transportation company or restaurant
a rider takes a trip or a delivery recipient receives an order arranged by a friend or under a family profile
5. With Us subsidiaries and affiliates
We share data with our subsidiaries and affiliates to help us provide our services or conduct data processing on our behalf. For example, We processes and stores such data in the United States on behalf of its international subsidiaries and affiliates, such as Cornershop. For more information, please visit our Cornershop Data Sharing Policy.
6. With Us service providers and business partners
payment processors and facilitators
background check and identity verification providers
cloud storage providers
Advertising intermediaries who enable app to display and measure the effectiveness of personalized ads.
marketing partners and marketing platform providers, including social media advertising services, advertising networks, third-party data providers, and other service providers to reach or better understand our users and measure advertising effectiveness
research partners, including those performing surveys or research projects in partnership with Us or on Our’s behalf
vendors that assist to enhance the safety and security of Our apps and services
consultants, lawyers, accountants, and other professional service providers
insurance and financing partners
providers of bike and scooters that can be rented through Our apps, such as Lime
third-party vehicle suppliers, including fleet and rental partners
7. For legal reasons or in the event of a dispute
we may share users’ data if we believe it’s required by applicable law, regulation, operating license or agreement, legal process or governmental request, or where the disclosure is otherwise appropriate due to safety or similar concerns.
This includes sharing data with law enforcement officials, public health officials, other government authorities, airports (if required by the airport authorities as a condition of operating on airport property), or other third parties as necessary to enforce our Terms of Service, user agreements, or other policies; to protect Our's rights or property or the rights, safety, or property of others; or in the event of a claim or dispute relating to the use of our services. In the event of a dispute relating to use of another person’s credit card, we may be required by law to share your data, including trip or order information, with the owner of that credit card.
This also includes sharing data with others in connection with, or during negotiations of, any merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or into another company.
8. With consent
We may share a user’s data other than as described in this notice if we notify the user and they consent to the sharing.
E. Data retention and deletion
We retains user data for as long as necessary for the purposes described above.
We retains user data to provide its services and comply with its legal obligations.
We retains user data for as long as necessary for the purposes described above. The period for which we retain user data is determined by the type of data, the category of user to whom the data relates, and the purposes for which we collected the data.
The length for which We retains user data may further be determined by legal and regulatory requirements, purposes of safety, security, and fraud prevention, or by issues relating to the user’s account such as an outstanding credit or an unresolved claim or dispute.
We retain user data of riders and order recipients that is processed in order to provide our services, such as the user profile information and credentials, for the lifetime of the user's account.
We retain certain categories of users for a maximum of 7 years regardless of the lifetime of the user's account, such as location data used to calculate the fee of the trip to comply with Tax regulations.
We retain certain categories of data of all users for a period unrelated to the lifetime of the user's account, to avoid fraudulent use of the app. The period for which the data is retained will be determined by the necessity of the data for purposes of safety, security, and fraud prevention, as well as legal and regulatory requirements. Examples include incomplete driver applications, which are retained for 1 year, and rejected driver applications and customer service communications on safety incidents, which are retained for 7 years.
Pursuant to legal and regulatory requirements, for purposes of safety, security, and fraud prevention, or because of an issue relating to the user’s account such as an outstanding credit or an unresolved claim or dispute, we may retain certain categories of data after the deletion of the user's account, such as user profile information, vehicle and tax data. This generally means that we retain their account and data for 7 years after a deletion request.
Users may request deletion of their accounts at any time. We may retain user data after a deletion request due to legal or regulatory requirements or for reasons stated in this policy.
Users may request deletion of their account at any time through the Settings > Privacy menus in the Our app, or through Our’s website (riders and order recipients here; drivers and delivery persons here; guest checkout users here).
Following an account deletion request, We deletes the user’s account and data, unless they must be retained due to legal or regulatory requirements, for purposes of safety, security, and fraud prevention, or because of an issue relating to the user’s account such as an outstanding credit or an unresolved claim or dispute. Because we are subject to legal and regulatory requirements relating to drivers and delivery persons, this generally means that we retain their account and data for the applicable statutory retention period after a deletion request. For riders and order recipients, their data is generally deleted within 90 days of a deletion request, except where retention is necessary for the above reasons.
IV. Choice and transparency
We enables users to access and/or control data that We collects, including through:
in-app ratings pages
We also enables users to request access to or copies of their data, make changes or updates to their accounts, request deletion of their accounts, or request that We restrict its processing of user data.
A. Privacy settings
The Settings > Privacy menu in the app allows riders and order recipients to set or update their preferences regarding location data collection and sharing, emergency data sharing, and notifications. Our Privacy Center is also available in web version.
Location data collection
User can enable/disable app to share their real-time location data from their mobile devices with their drivers through their device settings, which can be accessed via the Settings > My Profile > Address.
Emergency Data Sharing
We collects location data to track the location of drivers and show order status on the customer app so the customer easily tracks his order status through the app. When the app is closed or not in use, data is not trackable.
In the Agent app, we are tracking the location of the agent in the background mode as well while they are working for us, as soon as they mark their off Duty and clear the application from the background, we do not take the location or track the agent.
Users may enable app to send push notifications about discounts and news from App. Push notifications may be enabled or disabled through the Backend panel.
Communications from restaurants and merchants
While placing an order in the app, users may opt-in to share their contact details with certain restaurants or merchants in order to receive communications from them.
B. Device permissions
Most mobile device platforms (iOS, Android, etc.) have defined certain types of device data that apps cannot access without the device owner’s permission, and these platforms have different methods for how that permission can be obtained. Please check the available settings on your device or check with your provider.
C. In-app ratings pages
After every trip, drivers and riders are able to rate each other on a scale from 1 to 5. An average of those ratings is associated with a user’s account and is displayed to other users for whom they provide or receive services. For example, rider ratings are available to drivers from whom they request transportation, and driver ratings are available to their riders.
This 2-way system holds everyone accountable for their behavior. Accountability helps create a respectful, safe environment for drivers and riders.
Riders can see their average rating in the main menu of the app, and also access a breakdown of their average rating in Our’s Privacy Center.
Drivers can see their average rating after tapping their profile photo in the our Driver app. Click here for more information.
Delivery persons may also be rated by order recipients, restaurants and merchants. Click here for more information.
User data requests
we provides users with a variety of ways to learn about, control, and submit questions and comments about the handling of their data.
Accessing data: Users can access data including their profile data and trip or order history through Our apps or via website. Users can also use our Explore Your Data feature to view an online summary of information about their account, such as number of trips or orders, rating, rewards status, and number of days since they’ve been an Our user. Users can also request access to their data here.
Data portability: Users can request a copy of their data using our Download Your Data tool. For an overview of the data available through that tool, please click here. Users may also request a copy of their data here.
Changing or updating data: Users can edit the name, phone number, email address, payment method, and photo associated with their account through the Settings menu in Our's apps or driver portal. Users may also request to update or correct their data here.
Deleting Account: Users may request deletion of their account at any time through Our’s Privacy Center, or in the Settings and delete account.
In addition, depending on their location, users may have the right to file a complaint relating to handling of their data with the data protection authority in their country. For example, users in the European Union and South America may submit such requests to the data protection authorities in the country in which they live.