Village Cabs LTD
Privacy Policy
We, [] (“we” “our” or “us”) with our
registered office address at [1] are fully
committed to respecting your privacy and to protecting any information you
provide to us. We treat both privacy and security as a priority and make every
effort to ensure that all the information provided by you is protected. This
Data Protection Notice (the "Notice")
exists to respect and protect the privacy of all users of the services provided
by us (the "Services") and
is intended to inform you about the way that we treat your personal data.
1.
Scope
of Notice
This Notice applies in relation to the provision
of the Services and in particular to your use of, or engagement with, any or
all of the following (as applicable):
1.1.1
the VILLAGE
CABS software application (the “App”);
1.1.2
the VILLAGE
CABS website (the "Website"); and
1.1.3
any other
communications (whether over telephone, email, SMS message or otherwise)
between you and VILLAGE CABS in
connection with the provision of the Services.
This Notice sets out the basis on which any personal data we collect
from you or that you provide to us, in connection with your use of the Services
("Personal Data"), will be processed by us or our third-party service
providers. Please read the following carefully to understand our views and
practices regarding your personal data and how we will treat it.
For the purpose of the EU General Data
Protection Regulation (the "GDPR"),
the controller of your Personal Data is Our [Data Protection Officer Privacy
Compliance Manager] IS WAYNE YAPP
2.
YOUR PERSONAL DATA COLLECTED AND PROCESSED
IMPORTANT:
Please note that the below list of Personal Data, while intended to be as
complete and accurate as reasonably possible, is not exhaustive and may
be updated from time to time in accordance with Section 10 of this Notice.
2.1
We may
collect and process some or all of the following Personal Data about you (as applicable):
|
Data Collected |
Data Source(s) |
|
|
Information
you provide |
●
[You
provide us with information when you engage with us to use the Services,
create an account with us (either through our App, Website or by contacting
us through other means), download or install the App, and when you report a
problem with the Services, App or Website or when you correspond with us
generally in connection with your use of the Services. ●
The
information you provide to us may include but is not limited to your name,
address, e-mail address, address, phone number, age, date of birth,
username, password and other registration information, financial and credit
card information, and gender. ●
We may
collect demographic information about you, including through user surveys.][2] |
App, Website, Other
Communications |
|
Device
Information |
●
[Technical
information including but not limited to the type of device you use, a
unique device identifier (for example, network information, your operating
system, time zone setting and device locale)][3] |
App, Website |
|
Log
Information |
●
[Details
of your use of the Services including, but not limited to weblogs and/or
other communication data and the resources that you access][4] |
App, Website |
|
Location
Information |
●
[Depending
on how you choose to use the Services (that is, whether through use of our
App, Website or by contacting us through other means), we may collect
details of your location data to determine your current location.][5] |
App, Website |
|
Information
we receive from other sources |
●
[We work
with third parties (including, for example, service providers) and may
receive certain information from them about you that they choose to disclose
with us. This information may include your name, email, address and
location.][6] |
Other Communications |
|
Transaction
Information |
●
[We may
collect transaction details related to your use of the Services, including
the type of services you requested, your order details, delivery
information, date and time the service was provided, amount charged,
distance travelled, and payment method. We may also record details as to
whether or not a taxi journey is cancelled by you.][7] |
App, Website, Other Communications |
|
Usage
Information |
●
[We
collect information about how you interact with the Services. This includes
information such as access dates and times, App features or pages viewed,
App crashes and other system activity, type of browser, and third-party
sites or service you were using before interacting with the Services.][8] |
App, Website, Other Communications |
3.
HOW AND WHY WE PROCESS YOUR PERSONAL DATA
We, VILLAGE CABS in our capacity as controller, use the
information held about you on the following lawful bases and for the following
purposes:
|
Legal Basis |
Necessary for the Performance of a Contract |
|
Purposes |
It is necessary
to process your Personal Data to enter into and perform our contract with
you in relation to your use of the Services. We will process your Personal Data for the following purposes: ●
[To
create and maintain your account and profile, and, to facilitate your use of
the Services. ●
To help
you efficiently access your information after you sign into your App or
Website account. ●
In the
case of phone calls to village cabs to facilitate the Services by
communicating to drivers your name, number, location and destination. ●
To
enable and facilitate transportation from your location to your destination.
●
To
process or facilitate payments for the Services. ●
To track
the progress of your journey. ●
To
remember information so you will not have to re-enter it repeatedly when you
use the Services. ●
To
facilitate the provision of App or Website support, pop-up notifications and
other services. ●
To
improve the features and functionality of the App or Website to enhance your
experience. If you do not wish to provide us with your personal
data for these purposes, we will not be able to enter into or perform our
contract with you and you will not be able to use the Services. |
|
Legal Basis |
To Comply With a Legal Obligation |
|
Purposes |
We may process your Personal Data as necessary in order for
us: ●
To
comply with applicable Irish and European Union laws. ●
To
comply with requests from regulators, government entities and official
inquiries. |
|
Legal Basis |
Legitimate Interests |
|
Purposes |
It is in VILLAGE
CABS legitimate interests to collect
and process the Personal Data for the following purposes: ●
To
facilitate the Services being provided to you through utilisation of
third-party software. ●
To
monitor metrics such as total number of visitors, traffic and demographic
patterns. ●
To
prevent the corruption and/or loss of your Personal Data, to ensure the
security of our systems and to carry out regular testing to ensure the
smooth maintenance of our systems. You have the right to object at any time to the processing of
your personal data carried out on
this basis. When we process your personal data based on our
legitimate interests, we make sure to consider and balance any potential
impact on you and your data protection rights. We will not process your
personal data for activities where our interests are overridden
by the impact on you. |
4.
DISCLOSURE OF YOUR INFORMATION TO THIRD PARTIES
We, VILLAGE CABS may disclose some or all of the data we
collect from you in connection with your use of the Services to the following
third parties:
|
RECIPIENT |
|
●
Service Providers: Service providers who may use this
information to assist with the provision and improvement of the Services. In
particular, we will share your personal data with Taxi Alliance Software
Limited AND / OR Coolnagour Limited t/a iCabbi who provide software support
services to us in order to facilitate the provision of the Services to you. Our Service Provider may log certain information
concerning your use of the App or Website in relation to activities
connected with the use of the Services.
This information is logged for the purpose of providing the Services. The
information gathered is then aggregated and anonymised. From the anonymised
information collected, statistics may be compiled in the form of percentages
and/or figures relating to users’ interaction with the Services. As a
service, certain anonymised statistical information may be supplied to third
parties in order to help them understand the likes, dislikes, trends, habits
and behaviour of Service users. |
|
●
[Advertisers: We may provide advertisers with anonymous (not individual) aggregate information about our
users. We may also use such aggregate
information to help advertisers reach the kind of audience they want to
target. We do not disclose
information about identifiable
individuals to our advertisers.][9] |
|
●
VILLAGE CABS Group: We may disclose your personal information to
other members of our group, which means our subsidiaries, our ultimate
holding company and its subsidiaries.][10] |
|
●
Law Enforcement Agencies: We may disclose your information if we are under a duty to disclose
or share your personal data in order to comply with any legal or regulatory
obligation or request. |
|
●
[Buyers and Sellers of Business Assets: If VILLAGE CABS ] or substantially all of its
assets are acquired by a third party, personal data held by it about its
customers will be one of the transferred assets.][11] |
5.
LINKS TO THIRD PARTY WEBSITES
The App or Website may contain links
to and from the websites of our partner networks, advertisers and service
providers. If you follow a link to any of these websites, please note that
these websites and any services that may be accessible through them have their
own data protection notices and that we do not accept any responsibility or
liability for these notices or for any Personal Data that may be collected
through these websites or services, such as contact and location data. Please
check these notices before you submit any personal data to these websites or
use any such third party services.][12]
6.
STORING AND TRANSFERS OF YOUR PERSONAL DATA
We may transfer your Personal Data outside the
European Economic Area ("EEA").
Certain of our third party service providers who process your Personal Data on
our behalf may transfer your Personal Data outside the EEA to a country that
does not provide an adequate level of protection to your Personal Data.
Where such transfers occur, it is our policy
that: (i) they do not occur without our prior written authority; and (b) that
an appropriate transfer agreement such as the Standard Contractual Clauses or
other transfer mechanism approved by the European Commission and supervisory
authorities is put in place to protect your Personal Data. If you would like to
find out more about any such transfer, please contact our. All information you
provide to us is stored on our secure servers or the servers of our service
providers, contractors or suppliers.
Where we have given you (or where you have chosen) a password that
enables you to access the App or Website, you are responsible for keeping this
password confidential. We ask you not to share a password with anyone.
7.
HOW LONG WE KEEP YOUR PERSONAL DATA FOR
Village cabs will keep your Personal Data for as
long as you use the App or Website and for a period of 7 years after you delete
your account.][13]
Please note that in certain circumstances, we
may hold your Personal Data for a longer period, for example, if we are
processing an ongoing claim or believe in good faith that the law or a relevant
regulator may reasonably in our view expect or require us to preserve your
data.
8.
YOUR RIGHTS & HOW TO EXERCISE THEM
You have a number of rights in relation to your
Personal Data which are set out in this Section 8. In
particular these rights include the right to object to processing of your
personal data where that processing is carried out for our legitimate interests.
Note that in certain circumstances, these rights might not be absolute.
|
Right |
Further
Information |
|
Right
to be Informed |
●
You have
the right to know whether your personal data is being processed by us, how
we use your personal data and your rights in relation to your personal
data. |
|
Right
of Access |
●
You have
the right to request a copy of the personal data held by us about you. ●
We will
only charge you for making such an access request where we feel your request
is unjustified or excessive. ●
You may
also access your personal data by logging into your account on the App or
Website and viewing your profile. |
|
Right
to Rectification |
●
You have
the right to request that we amend any inaccurate personal data that we have
about you. |
|
Right
to Erasure |
●
You have
the right to ask us to erase your personal data where: (1) it is no longer necessary to perform the
contract (2) you withdraw your consent and there is no
other legal basis permitting us to process your personal data (3) you object to the processing and we have no
overriding legitimate grounds (4) your personal data have been unlawfully
processed; or (5) it must be erased to comply with a legal
obligation. ●
Please
note that some of your personal data may be required in order for the App to
function properly. |
|
Right
to Restriction of Processing |
●
You have
the right to ask us to restrict processing your personal data in the
following situations: (1) where you contest the accuracy of your
personal data (2) where the processing is unlawful and you do
not want us to delete your personal data (3) where we no longer need your personal data
for the purposes of processing but you require the data in relation to a
legal claim (4) where you have objected to us processing your
personal data pending the verification as to whether or not our legitimate
interests override your interests or in connection with legal proceedings. ●
When you
exercise this right we may only store your personal data. ●
We may
not further process the data unless you consent or the processing is
necessary in relation to a legal claim or to protect the rights of another
person or legal person or for reasons of important public interest. ●
Please
note that it may be necessary for us to process some of your personal data
in order to provide the App or Website and in certain instances where you
ask us not to process your personal data you may not be able to use the App
or Website. ●
We will
inform you before the processing restriction is lifted. |
|
Right
to Data Portability |
●
You may
request us to provide you with your personal data which you have given us in
a structured, commonly used and machine-readable format and you may request
us to transmit your personal data directly to another data controller where
this is technically feasible. ●
This
right only arises where: (1) we process your personal data on the legal
bases of your consent or where it is necessary to perform our contract with
you; and (2) the processing is carried out by automated
means. |
|
Right
to Object |
●
You have
a right to object at any time to the processing of your personal data where
we process your personal data on the legal basis of pursuing our legitimate
interests. |
|
Right to Object to Automated Decision-Making,
including Profiling |
●
You have
a right not to be subject to a decision based solely on automated
processing, including profiling, which produces legal effects concerning you
or similarly significantly affects you. ●
We may
not be able to comply with this request where the processing is necessary to
enter or perform our contract with you or where you explicitly consent to
this. However, you are entitled to have a person from our team to review the
decision so that you can query it and set out your point of view to us. |
You can exercise any of these rights by
submitting a request in writing to VILLAGECABS2020@OUTLOOK.COM
9.
[AGE
RESTRICTION
Individuals under the age of 18 are not eligible
to use the Services and must not attempt to register and/or submit any personal
information to us. We do not knowingly collect personal information from any
person who is under the age of 18 or allow them to register. If it comes to our
attention that we have collected personal data from a person under the age of
18, we will delete this information as soon as reasonably possible. If you have
reason to believe that this has occurred, please contact us at VILLAGECABS2020@OUTLOOK.COM
10.
CHANGES TO THIS NOTICE & QUESTIONS
[Any material
changes we may make to the Notice in the future will be notified to you by
e-mail or pop-up notification when you next start the App or visit the
Website.][14] The new Notice may be displayed on-screen and
you may be required to read and accept them to continue your use of the App or
the Website.
If at any time we
decide to use your Personal Data in a manner significantly different from that
stated in this notice, or otherwise disclosed to you at the time it was
collected, we will notify you BY EMAIL and you will have a choice as to whether
or not we use your Personal Data in the new manner.
Questions, comments
and requests regarding this Notice and the way your Personal Data is being used
or processed by us are welcomed and should be submitted to our DIRECTOR Wayne
Yapp