Privacy Policy

Background

Navhoo understands that your privacy is important to you and that you care about how your information is used and shared online. We respect and value the privacy of everyone who visits Our Web Site and will only collect and use information in ways that are useful to you and in a manner consistent with your rights and Our obligations under the current GDPR regulations.

This Notice applies to Our use of any and all data collected by us in relation to your use of Our web Site. Please read this Privacy Notice carefully and ensure that you understand it. Your acceptance of Our Privacy Notice is deemed to occur upon your first use of Our web Site. If you do not accept and agree with this Privacy Notice, you must stop using Our web Site immediately.

1. Definitions and Interpretation

In this Notice the following terms shall have the following meanings:

2. Data Protection Officer

• Our data protection officer can be contacted at dpo@navhoo.com.

3. Scope – What Does This Notice relate to?

This Privacy Notice applies only to your use of Our Web Site. It does not extend to any websites that are linked to from Our Web Site (whether We provide those links or whether they are shared by other users). We have no control over how your data is collected, stored or used by other websites and We advise you to check the privacy notices of any such websites before providing any data to them.

4. What Data Do We Collect?

Some data will be collected automatically by Our Web Site, other data will only be collected if you voluntarily submit it and consent to Us using it for the purposes set out in section 5, for example, when signing up for an Account. Depending upon your use of Our Web Site, We may collect some or all of the following data:

1. Information you give us:

• This is information about you that you give us directly when you interact with us. The GDPR privacy law requires us to explain to users, for each category of information we collect, why we collect it and for what reason.

• Personal Data type collected from Users and Drivers

  • First Name
  • Email;
  • Profile image/ Photo (optional for Users);
  • Date of birth (for Driver Partners only);
  • Gender (for Driver Partners only);
  • Home address.
  • Mobile number (including country).

• Payment information:

  • for Users, this includes billing information, credit card details and your student/senior status (where appropriate);
  • for Driver Partners, this may include bank account details.
  • For Users, feedback you provide on Driver Partners.

• In relation to Users only:

  • Technical details:
  • App version;
  • User ID (unique ID our platform assigns to each User);
  • Build;
  • Operating system;
  • Phone make/ model.
  • Dates and times of Rides requested and fulfilled;
  • Cost of Ride;
  • Remaining credit
  • Driving history (usage of Navhoo’ s Service) – driving times; ratings; feedback from Rides; escalation/ incident history);
  • Routes used (in relation to Driver Partners, this includes data on the differences between actual route taken and route instructed by Navhoo’ s system);
  • Trip records.
  • Preferred language/ language settings on device.
  • Communications – SMSs and emails between Navhoo/Driver Partner/Users.
  • For analysis and report generation purposes (including developing new features, support service improvements on payments, pricing, routing, algorithmic dispatching efficiencies, for quality of Service review and fraud detection);
  • Improve service functionality and efficiency;
  • Prevention of fraud/ integrity of systems and manage accounts.
  • To optimize and personalize the user experience on the App;
  • In relation to Users, customer service.
  • Provision of Services;
  • Internal operations (including troubleshooting, data analysis, testing, research, statistical and survey purposes)
  • Improve service functionality and efficiency;
  • Prevention of fraud/ integrity of systems and manage accounts;
  • To optimise and personalise the user experience on the App;
  • In relation to Users, Customer service.

• For Driver Partners – Data Collected

  • Vehicle information and condition – picture of car (inside and out) and presence of in car equipment;
  • Insurance information;
  • Any licence or permission Driver Partner has or needs under local regulations;
  • Driver’s license;
  • Vehicle registration;
  • Road or other tax details for Driver Partner or vehicle (where required);
  • Traffic violations (including accidents) occurred on the mobile application;
  • Ticket, fines and violations;
  • Background check.

• Purpose of processing for Users & Drivers

  • Set-up and manage the account;
  • Provision of Services;
  • Customer services;
  • Internal operations (including troubleshooting, data analysis, testing, research, statistical and survey purposes);
  • For analysis and report generation purposes (including developing new features, support service improvements on payments, pricing, routing, algorithmic dispatching efficiencies, for quality of Service review and fraud detection);
  • Improve service functionality and efficiency;
  • Prevention of fraud/ integrity of systems and manage accounts;
  • In relation to Driver Partners, for background checks to assess suitability of Driver Partners and protect Users;
  • In relation to Driver Partners, to investigate ratings, User feedback and complaints;
  • Promote similar Services to you,
  • Set-up and manage account;
  • Provision of Services and required communications in relation to the provision of Services;
  • Communicate with you in relation to a Ride;
  • If you are a Driver Partner, promote the Services to you.

• Users:

  • Our legitimate interests in authenticating authorised Users so we can provide the Service, and enable Users to connect with Driver Partners and, promote the use of the Services to them, and as is necessary for the purpose of the contract in order to provide the Service.

• Driver Partners:

  • Our legitimate interests and as is necessary for the purpose of the contract between Navhoo and the Driver Partner.

5. How Do We Use Your Data?

• All personal data is stored securely in accordance with the EU General Data Protection Regulation (Regulation (EU) 2016/679) (GDPR). For more details on security see section 6, below.
• We use your data to provide the best possible services to you. This includes:
  • Providing and managing your access to Our Web Site;
  • Personalising and tailoring your experience on Our Web Site;
  • Supplying Our services to you;
  • Personalising and tailoring Our services for you;
  • Responding to communications from you;
• In some cases, the collection of data may be a statutory or contractual requirement, and We will be limited in the services We can provide you without your consent for Us to be able to use such data
• We may also use your data for communication purposes which may include contacting you by support@navhoo.com with information, news and offers on Our services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, as amended in 2004, 2011 and 2015.
• Under GDPR we will ensure that your personal data is processed lawfully, fairly, and transparently, without adversely affecting your rights.

6. How and Where Do We Store Your Data?

• We only keep your data for as long as We need to in order to use it as described above in section 5. In any event, We will conduct an annual review to ascertain whether we need to keep your data. Your data will be deleted if we no longer need it in accordance with the terms of our Data Retention Notice.
• Your data will only be stored within the European Economic Area (“the EEA”) and the UK.
• Data security is of great importance to Us, and to protect your data We have put in place suitable physical, electronic and managerial procedures to safeguard and secure data collected through Our Web Site.
• Notwithstanding the security measures that We take, it is important to users that the transmission of data via the internet may not be completely secure and that you are advised to take suitable precautions when transmitting to Us data via the internet.

7. Do We Share Your Data?

• We do not share your data with any Parties unless legally required to.

8. What Happens If Our Business Changes Hands?

• We may, from time to time, expand or reduce Our business and this may involve the sale and/or the transfer of control of all or part of Our business. Data provided by users will, where it is relevant to any part of Our business so transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Privacy Notice, be permitted to use the data for the purposes for which it was originally collected by Us.

9. Your Rights as per GDPR

• You may access certain areas of Our Web Site without providing any data at all. However, to use all features and functions available on Our Web Site you may be required to submit or allow for the collection of certain data.

10. How Can You Access Your Data?

• You have the legal right to ask for a copy of any of your personal data held by Us (where such data is held).Please contact Us for more details at DPO@navhoo.com, or using the contact details below in section 14.

11. Summary of Your Rights under GDPR

Under the GDPR, you have:

• the right to request access to, deletion of or correction of, your personal data held by Us;
• the right to complain to a supervisory authority;
• be informed of what data processing is taking place;
• the right to restrict processing;
• the right to data portability;
• object to processing of your personal data;
• rights with respect to automated decision-making and profiling (see section 14 below).
• To enforce any of the foregoing rights or if you have any other questions about Our Web Site or this Privacy Notice, please contact Us using the details set out in section 15 below.

12. What Cookies Do We Use and What For?

• Our Web Site may place and access certain first party Cookies on your computer or device. First party Cookies are those placed directly by Us and are used only by Us. We use Cookies to facilitate and improve your experience of Our Web Site and to provide and improve Our services. We have carefully chosen these Cookies and have taken steps to ensure that your privacy is protected and respected at all times.
• By using Our Web Site you may also receive certain third party Cookies on your computer or device. Third party Cookies are those placed by websites, services, and/or parties other than Us.
• All Cookies used by and onOur Web Site are used in accordance with current English and EU Cookie Law.
• Before Cookies are placed on your computer or device,you will be shown a pop-up, message bar requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling Us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of Our Web Site may not function fully or as intended. You will be given the opportunity to allow only first party Cookies and block third party Cookies.
• Our Web Site uses analytics services provided by Google Analytics. Website analytics refers to a set of tools used to collect and analyse usage statistics, enabling Us to better understand how people use Our Web Site. This, in turn, enables Us to improve Our Web Site and the services offered through it. You do not have to allow Us to use these Cookies, as detailed below, however whilst Our use of them does not pose any risk to your privacy or your safe use of Our Web Site, it does enable Us to continually improve Our Web Site, making it a better and more useful experience for you.
• The analytics service(s) used by Our Web Site use(s) Cookies to gather the required information.
• You can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all cookies or only third party cookies. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.
• You can choose to delete Cookies at any time however you may lose any information that enables you to access Our Web Site more quickly and efficiently including, but not limited to, login and personalisation settings.
• It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.

The tables below list some of the internal and third-party cookies we use. As the names, numbers, and purposes of these cookies may change over time, this page may be updated to reflect those changes. For more information on how we use these cookies, please refer to our Cookies Notice.

12.1 Third-Party Cookies:

13. Automated Decision-Making and Profiling

• In the event that We use personal data for the purposes of automated decision-making and those decisions have a legal (or similarly significant effect) on You, You have the right to challenge to such decisions under GDPR, requesting human intervention, expressing their own point of view, and obtaining an explanation of the decision from Us.
• The right does not apply in the following circumstances:
  • a) The decision is necessary for the entry into, or performance of, a contract between the You and Us;
  • b) The decision is authorised by law; or
  • c) You have given you explicit consent.
• Where We use your personal data for profiling purposes, the following shall apply:
  • a) Clear information explaining the profiling will be provided, including its significance and the likely consequences;
  • b) Appropriate mathematical or statistical procedures will be used;
  • c) Technical and organisational measures necessary to minimise the risk of errors and to enable such errors to be easily corrected shall be implemented; and
  • d) All personal data processed for profiling purposes shall be secured in order to prevent discriminatory effects arising out of profiling.

14. Contacting Us

If you have any questions about Our Web Site or this Privacy Notice, please contact Us by email at support@navhoo.com, or by post at 305 Keys Court, 82-84 Moseley Street, Birmingham. B12 0RT. Please ensure that your query is clear, particularly if it is a request for information about the data we hold about you.

15. Changes to Our Privacy Notice

We may change this Privacy Notice as we may deem necessary from time to time, or as may be required by law. Any changes will be immediately posted on Our Web Site and you will be deemed to have accepted the terms of the Privacy Notice on your first use of Our Web Site following the alterations. We recommend that you check this page regularly to keep up-to-date.