Last Updated: March 4th, 2022
1.2 A Note About Children. We do not intentionally gather Personal Information (defined in Collection of Information below) from persons who are under the age of 13. If someone submits Personal Information to RideCo and we learn that the Personal Information is the Personal Information of a child under 13, we will attempt to delete the Personal Information as soon as possible. If you believe that we might have any Personal Information from a child under 13, please contact us at: firstname.lastname@example.org.
2. COLLECTION AND USE OF PERSONAL INFORMATION
2.1 What We Collect. Set out below are the ways in which we may collect Personal Information:
· Personal Information We Collect from Customers. We may collect business contact information of individuals who work for our customers (e.g., employees of transit authorities who we partner with to provide regional services) in order to communicate with those customers about their business relationship with RideCo. We may also collect payment credentials or related information from the customers in order to allow those customers to pay RideCo for Services procured by such customers or in order to remit to such customers their share of transaction fees collected from end users.
· Device information. We may collect information about devices you use to access the Services and information about how you use the Services, such as your IP address and which websites you visited before accessing our Services.
· Logs. Our servers and those of our third-party service providers automatically record information created by your use of our Services to help us diagnose and fix technical issues, and to improve the overall quality and user experience of our Services. Logs may include information such as your IP address, browser type, operating system, details of how you used our Services (such as the functions you asked our Services to perform), diagnostic information related to the Services (such as crash activity reports), the referring web page, pages visited, location, your mobile carrier, device and application IDs, search terms, and cookie information.
· Cookies. We (and our third-party service providers) use technologies like cookies and pixel tags to gather information about how you are interacting with the Services, which may include identifying your IP address, browser type, and referring page.
· Employee and Contractor Candidate Information. When we seek candidates for potential jobs or contracting engagements with RideCo, we collect information that those candidates choose to provide to us when applying, which may include contact information, education and employment history, credentials, place of residence and other information the candidate believes to be relevant. For people who become our employees or contractors, we will typically retain the information provided by those candidates in the application process along with additional information to manage their employment or contractor relationship with us, including, without limitation, information related to income tax reporting and withholding and enrollment in RideCo benefit plans (in each case, to the extent applicable for the relevant relationship).
· Marketing and Marketing Information. You acknowledge and agree that we may communicate with you from time to time to inform you of other services, features or functionalities of our Services; let you know of any surveys, newsletters, offers, promotions or contests, and events we may run or hold; provide you with other news or information about us and our select partners (including from our clients), serve advertisements and we may use your personal information to monitor and analyze trends, usage, and activities in connection with the Service including to improve and tailor our products and services and to improve our marketing and promotional efforts. In the course of any such activities or your communications with us, we may collect information you elect to provide about yourself, such as your name, email address, telephone number, organization name and address; and general information about the company for whom you work if applicable). In addition, we may use third-party service providers to collected business-related information about your employer such as its name, size, and publicly available revenue in connection with potentially offering the Services to your employer.
· RideCo Suppliers and Partners. RideCo collects business contact information of individuals who work for our suppliers and other partners to communicate with those suppliers and partners about their business relationship with RideCo.
· Driver Information. Drivers will be required to provide us with personal information including their full name, vehicle make and model, license plate, vehicle registration, driver’s license and proof of insurance. We may use this information for verification purposes including to perform background checks by us or third parties. Riders will be able to view the first name, photo, type of vehicle and license plate of Drivers assigned to them. We may use this information for business purposes, including for marketing, lead generation, service development and improvement, analytics, industry and market research, obtaining and maintaining insurance, and such other purposes consistent with RideCo’s and its affiliate’s legitimate business needs.
· Driver Location Information. We will collect vehicle location data through a mobile application registered to the Driver. If you are a Driver, you expressly consent to RideCo’s use of vehicle location data for business purposes, including for communicating the vehicle location to Riders, for vehicle routing, estimating transit times, for making adjustments to ride-share itineraries, for evaluating your adherence to the scheduled itinerary, to assess your performance, to enhance our Services, to facilitate the investigation, settlement and/or resolution of insurance claims inquiries or investigations, and other such purposes consistent with RideCo’s and its affiliate’s legitimate business needs. Accordingly, you (as a Driver) agree that (a) RideCo (including all of its successors and assigns and any successors and assigns of any of the RideCo Offerings) may freely use, reproduce, license, distribute, and otherwise commercialize aggregate, non-personal driver location information in any RideCo Offerings, and (d) you are not entitled to receive any compensation or re-imbursement of any kind from RideCo for use of said driver location information.
· Statistics. We also collect statistics about use of the Services, for example how frequently you use our Services, the average length of rides you take using our Services, the routes that are taken, and how many people you typically share a ride with. We aggregate such information about our users to create analytics including predictive analytics such as traffic usage and route usage patterns. Aggregate statistics that do not personally identify an individual will be kept by us and may be made available to other members or third parties or publicly. We may disclose and display aggregated, de-identified data publicly, for example, to show our usage trends.
2.2 Use of Personal Information. RideCo uses the Personal Information described above to:
· provide your first name, pickup and drop off location to drivers assigned to pick you up;
· verify end user’s identities for the purposes of know-your-customer laws and regulations;
· provide, operate, maintain and improve the Services;
· send technical notices, updates, security alerts and support and administrative messages;
· complete transactions and send related information to the relevant transaction participants, including confirmations and invoices;
· respond to comments, questions, and requests and provide customer service and support;
· communicate with you and provide news or information about us;
· investigate and prevent fraudulent transactions, unauthorized access to the Services, and other illegal activities;
· monitor and analyze trends, usage, and activities in connection with the Services, including generating aggregated and anonymized statistics;
· give drivers the ability to call you or send messages to you through the Services in connection with an upcoming ride you may have booked. This information is made available to the Driver immediately prior to your pick-up in order to facilitate your pick-up in a timely and convenient manner;
· conduct business and contractual relationships that we have with various persons and companies(such as customers, suppliers, partners and employees); and
· for other purposes which we will notify you about and seek your consent.
3. STORAGE LOCATION AND TRANSFER OF PERSONAL INFORMATION
RideCo processes and stores its data, including Personal Information, on servers located in Canada, the United States and the EEC. RideCo also transfers data to third-party service providers, including the third-party service providers described on our Sub-Processors webpage, available at: www.rideco.com/sub-processors (“Sub-Processors”). You agree to this transfer, storing or processing of your Personal Information in Canada and United States. You acknowledge and agree that your Personal Information may be accessible to law enforcement and governmental agencies in Canada and the United States under lawful access regimes or court order.
4. DISCLOSURE OF PERSONAL INFORMATION WITH THIRD PARTIES
4.1 Service Providers and Business Partners. We may from time to time employ third parties to perform tasks for us and we may need to share Personal Information (including account information) with them to perform those tasks. Unless we tell you differently, such third parties do not have any right to use the Personal Information we share with them beyond what is necessary for them perform the relevant tasks for us. The third parties we currently engage include third-party companies and individuals employed or contracted by us to provide certain capabilities within the Services and for certain general business functions, including the provision of database management, payment processing and customer relationship management tools, including the Sub-Processors.
4.4 Incidents and Insurance Claims. We will collect and disclose your information to insurance companies and to any party that is directly involved in an insurance claims situation which involves or which the party reasonably believes involves the transportation of paying passengers, to facilitate the investigation, settlement and/or resolution of the claims inquiry or investigation. Such information will include your name, address, phone number and email. Such information will also include, but not be limited to, other information collected by us that is relevant to the insurance claim inquiry or investigation, such as your location at the time of the incident or accident and the status of the App at the time of and in the 12-hour period prior to and following the incident or accident.
4.5 Payments. All payments are facilitated through third party payment processing services, namely Braintree, a division of PayPal, Inc., and/or Stripe. We reserve the right to change payment processors, subject to the terms of our agreement with our processors. Any updates to payment processors will be reflected in an update to our list of Sub-Processors: www.rideco.com/sub-processors.
4.6 As Required by Law. We may disclose your Personal Information to third parties without your consent if we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be causing injury to or interference with (either intentionally or unintentionally) our rights or property, other users, or anyone else (including the rights or property of anyone else) that could be harmed by such activities. Further, we may disclose Personal Information when we believe in good faith that such disclosure is required by and in accordance with the law.
We also reserve the right to access, read, preserve, and disclose any information as we reasonably believe is necessary to:
· satisfy any applicable law, regulation, legal process or governmental request (including in pursuant to subpoenas, civil investigative demands, or similar processes); enforce our contracts or user agreements, including investigation of potential violations hereof; and
· detect, prevent, or otherwise address fraud, security, or technical issues.
6. RESIDENTS OF THE EUROPEAN ECONOMIC COMMUNITY (“EEC”) AND THE UK
If you are a resident of the EEC or the UK, you have certain data protection rights. RideCo takes reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Information (known as “Personal Data” under the EU General Data Protection Regulation and under the UK Data Protection Act 2018).
If you wish to be informed about what Personal Data we hold about you and if you want that Personal Data to be removed from our systems, please contact us using the contact information set out below. Note that where we act as a data processor on behalf of our customers, you will be required to contact the data controller directly to exercise your rights.
In certain circumstances, where we act as data controller, you have the following data protection rights:
· Request access to your Personal Data (commonly known as a “data subject access request”). This enables you to receive a copy of the Personal Data we hold about you where we are the data controller and to check that we are lawfully processing it.
· Request correction of the Personal Data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected, though we may need to verify the accuracy of the new information you provide to us.
· Request erasure of your Personal Data. This enables you to ask us to delete or remove Personal Data where there is no good reason for us to continue to process it. You also have the right to ask us to delete or remove your Personal Data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully, or where we are required to erase your Personal Data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
· Object to processing of your Personal Data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your Personal Data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
· Request restriction of processing of your Personal Data. This enables you to ask us to suspend the processing of your Personal Data in the following scenarios: (a) if you want us to establish the information's accuracy; (b) where our use of the information is unlawful but you do not want us to erase it; (c) where you need us to hold the information even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your information but we need to verify whether we have overriding legitimate grounds to use it.
· Request the transfer of your Personal Data to you or to a third party. We will provide to you, or a third party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Note, that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
· Withdraw consent at any time where we are relying on consent to process your Personal Data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.
Please note that we may ask you to verify your identity before responding to such requests.
You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local Data Protection Authority. If you wish to exercise any of the rights set out above, please contact us using the contact details below.
You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it.
We may also contact you to ask you for further information in relation to your request to speed up our response.
7. ACCESS, CORRECTION AND ACCURACY
You have the right to access the Personal Information we hold about you in order to verify the Personal Information we have collected in respect to you and to have a general account of our uses of that Personal Information. Upon receipt of your written request, we will provide you with a copy of your Personal Information, although in certain limited circumstances, and as permitted under law, we may not be able to make all relevant Personal Information available to you, such as where that Personal Information also pertains to another individual. In such circumstances we will provide reasons for the denial to you upon request. We will endeavor to deal with all requests for access to and modifications of Personal Information in a timely manner.
We will make every reasonable effort to keep your Personal Information accurate and up to date, and we will provide you with mechanisms to update, correct, delete or add to your Personal Information as appropriate. As appropriate, this amended Personal Information will be transmitted to those parties to which we are permitted to disclose your Personal Information. Having accurate Personal Information about you enables us to give you the best possible service.
8. CALIFORNIA PRIVACY RIGHTS
This section provides additional details about the Personal Information we collect about California consumers and the rights afforded to them under the California Consumer Privacy Act (the CCPA).
For more details about the Personal Information RideCo has collected over the last 12 months, please see the section “Information you provide us” above. We collect this Personal Information for commercial purposes described above. RideCo does not sell (as that term is defined in the CCPA) the Personal Information we collect.
Subject to certain limitations, the CCPA provides California consumers the right to request to know more details about the categories or specific pieces of Personal Information we collect about them (including how we use and disclose this Personal Information), to delete their Personal Information, to opt out of any “sales” of Personal Information that may be occurring, and to not be discriminated against for exercising these rights.
California consumers may make a request pursuant to their rights under the CCPA by contacting us at the contact information below. We will verify your request using the information (including Personal Information) associated with your account, if available, including email address. Government identification may be required. Consumers can also designate an authorized agent to exercise these rights on their behalf.
10. ADDITIONAL INFORMATION
You can help by keeping us informed of any changes such as a change of email address or telephone number. If you would like to access your information, if you have any questions, comments or suggestions, or if you find any errors in our information about you, please contact us by e-mailing us at: email@example.com.