RIDERS PRIVACY POLICY

This policy applies to your use of the Zareou mobile application software (App) hosted on zareou.com (App Site), once you have downloaded or streamed a copy of the App onto your mobile telephone or handheld device (Device). Any of the services accessible through the App (Services) that are available on the App Site. This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our practices regarding your personal data and how we will treat it.

Important information and who we are

Zareou Limited (crn 10394894) is the controller and is responsible for your personal data (collectively referred to as “Company”, “we”, “us” or “our” in this policy).

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues.

  • Please note that we transfer data to our partners in India and we do not profile (use technology to make decisions regarding your personal data)
  • Changes to the privacy policy and your duty to inform us of changes
  • We keep our privacy policy under regular review. This version was last updated on 28th of September 2020. It may change and if it does, these changes will be posted on this page and notified to you when you next start the App or log onto our website. The new policy may be displayed on-screen and you may be required to read and accept the changes to continue your use of the App or other services that we may offer.
  • It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during our relationship with you.

The data we collect about you

We may collect, use, store and transfer different kinds of personal data about you as follows:

  • Identity Data: first name, last name, maiden name, username or similar identifier, marital status, title, date of birth, gender.
  • Contact Data: billing address, email address and telephone numbers.
  • Financial Data: payment card details.
  • Device Data: includes the type of mobile device you use – a unique device identifier (for example, your Device’s IMEI number, the MAC address of the Device’s wireless network interface, or the mobile phone number used by the Device).
  • Usage Data: includes details of your use of the App or your visits to the App Site including, but not limited to, traffic data and other communication data, whether this is required for our own billing purposes or otherwise.
  • Location Data: includes your current location disclosed by GPS technology.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

How is your personal data collected?

We will collect and process the following data about you:

  • Information you give us. This is information you share with us when you register and use our services.
  • Information we collect about you and your device. Each time you visit the App Site or use our App we will automatically collect personal data including Device and Usage Data. We collect this data using cookies and other similar technologies. Please see Cookies section below for further details.
  • Location Data. We also use GPS technology to determine your current location so that our driver can collect you. If you have enabled us to collect location data from their mobile device may also enable us to share their location with their driver from the time the ride is requested to the start of the trip. This can help improve pickups for both drivers and riders, particularly in crowded areas.

Cookies

We use cookies and/or other tracking technologies to distinguish you from other users of the App, and to remember your preferences. This helps us to provide you with a good experience when you use the App or browse the App Site and also allows us to improve the App and App Site. For detailed information on the cookies we use, the purposes for which we use them and how you can exercise your choices regarding our use of your cookies, see our cookie policy at the end of this page.

How we use your personal data

We will only use your personal data when the law allows us to do so. Most commonly we will use your personal data in the following circumstances:

  • Using our App to arrange transport is a contractual obligation. We will process your personal data to meet our contractual obligations. This includes creating and updating user’s accounts; enabling drivers to contact users to confirm the user’s requirements and facilitating payment for our services.
  • To offer Customer support we use the information we collect (including recordings of customer support calls with notice to and the consent of the user) to provide customer support, including to investigate concerns; and monitor and improve our customer support responses and processes
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. This includes updating you on our services and any increased functionality. You can “unsubscribe”.
  • To allow us to personalize users’ accounts, listing favourite places and previous destinations.
  • To administer and protect our business and this App including troubleshooting, data analysis, monitoring trends so we can improve the App and system testing. Again, this is necessary for our legitimate interests.
  • Where we need to comply with a legal or regulatory obligation. This involves maintaining accurate financial data and when necessary liaising with law enforcement and Government bodies such as HMRC.

Disclosures of your personal data

We will work with reputable third-party payment providers on whom we will have conducted due diligence regarding how they handle privacy.

We from time to time may share your personal data with the third parties. This will be done in accordance with the purpose for which we process your personal data. The third parties may include any company to which we outsource our services or collaborate with.

We will transfer your personal data to Dex Consulting in India on the strict understanding that Dex Consulting follows the same rules when processing your personal data. We use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA. 

Data security

All information you provide to us is stored on our secure servers. Any payment transactions carried out by us or our chosen third-party provider of payment processing services will be encrypted using 256-bit encryption. Where we have given you (or where you have chosen) a password that enables you to access certain parts of the App Site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Once we have received your information, we will use strict procedures and security features to try to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way.

We will collect and store personal data on your Device using application data caches *.

Data retention

By law we have to keep basic information about our customers for six years after they cease being customers for tax purposes.

Unless you do not use the App for a year when we will treat the account as expired, we will keep your account open and contact you as set out in this policy. If you “deactivate” your account. On cessation of membership your personal data will remain dormant but retained for the above purpose any personal data we do not need will be deleted.

Please note that we may be unable to delete a user’s account, such as if there’s an outstanding credit on the account or an unresolved claim or dispute. Upon resolution the account will be closed. 

Your legal rights

Under certain circumstances you have the following rights under data protection laws in relation to your personal data.

  • 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 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 data we hold about you corrected, though we may need to verify the accuracy of the new data 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 continuing 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:

if you want us to establish the data’s accuracy;

where our use of the data is unlawful but you do not want us to erase it;

where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or you have objected to our use of your data 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 products or services to you. We will advise you if this is the case at the time you withdraw your consent.

DRIVERS PRIVACY POLICY

This policy is issued to those who register as drivers and includes personal data:

  1. processed on the Zareou mobile application software (App) hosted on zareou.com (App Site);
  2. processed by us in order to meet any obligations we owe to you as the company that engages your services as a driver;
  3. of drivers who no longer work for us.

This policy is not contractual and does not form a part of any contract of service or contact for services.

Please note that this policy sets out how we process special category (formerly known as sensitive personal data) and criminal records data.

Important information and who we are

Zareou Limited (crn 10394894) is the controller and is responsible for your personal data (collectively referred to as “Company”, “we”, “us” or “our” in this policy).

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues.

Please note:

  • we transfer data to our partners in India and we do not profile (use technology to make decisions regarding your personal data).
  • We keep this privacy policy under regular review. This version was last updated on 28th September 2020. It may change and if it does, these changes will be posted on this page and notified to you when you next start the App or log onto our website. The new policy may be displayed on-screen and you may be required to read and accept the changes to continue your use of the App or other services that we may offer.
  • It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during our relationship with you.

The data we collect about you

We may collect, use, store and transfer different kinds of personal data about you as follows:

  • Identity Data: first name, last name, maiden name, username or similar identifier, marital status, title, date of birth, gender, profile picture, national insurance number, government identification documents, including driver’s license numbers and images, birthdate, signature, and photo. This also includes your vehicle or insurance information.
  • User Data, such as ratings, feedback, or compliments.
  • Services Data: Recruitment information (including copies of right to work documentation, references and other information included as part of the application process) worker records (including job titles, work history, working hours, compensation history, performance information, disciplinary and grievance information). For those providing services through a personal service company the results of any HMRC employment status check, details of your interest in and connection with the intermediary through which your services are supplied.
  • Contact Data: postal address; email address; next of kin details and telephone numbers.
  • Financial Data: your bank account details.
  • Device Data: includes the type of mobile device you use – a unique device identifier (for example, your Device’s IMEI number, the MAC address of the Device’s wireless network interface, or the mobile phone number used by the Device).
  • Location Data: includes your current location disclosed by GPS technology.

We may also collect, store and use the following more sensitive types of personal information (otherwise known as Special Category Data):

  • Information about your race or ethnicity, religious beliefs, sexual orientation and political opinions.
  • Information about your health, including any medical condition, health and sickness records, including
  • Information about criminal convictions and offences.

How is your personal data collected?

We will collect and process the following data about you:

  • Information you give us. This is information you share with us when you apply to be a driver.
  • Information we collect about you and your device. Each time you visit our App Site or use our App we will automatically collect personal data including Device and Usage Data. We collect this data using cookies and other similar technologies. Please see Cookies section below for further details.
  • Information we obtain from Third Parties. We will liaise with the local council where you are registered; DVLA and any organisation that has granted you a licence and personal data will be exchanged. User data will be disclosed by our users.
  • Location Data. We also use GPS technology to determine your current location so that our driver can collect you

Cookies

We use cookies and/or other tracking technologies to distinguish you from other users of the App, and to remember your preferences. This helps us to provide you with a good experience when you use the App or browse the App Site and also allows us to improve the App and App Site. For detailed information on the cookies we use, the purposes for which we use them and how you can exercise your choices regarding our use of your cookies, see our cookie policy at the end of this page.

How we use your personal data

We will only use your personal data when the law allows us to do so. Most commonly we will use your personal data in the following circumstances:

  • we may use the photos submitted by drivers and/or delivery partners to verify their identities, such as through facial recognition technologies.
  • Background check and identity verification: We collect background check and identity verification information for drivers. This may include information such as driver history or criminal record (where permitted by law), and right to work. We may outsource this verification to a third party.
  • We will use your personal data to decide whether to offer you work and if we do so to communicate with you; pay you your emoluments and manage our working relationship and its termination.
  • We will share with you any feedback; results from surveys; criticism or compliments.
  • We will use data from your Device to help us track your location. We may also use this data to identify unsafe driving behaviour, and if necessary, to inform you of safer driving practices.
  • We may use data from your Device, location, profile, usage, and other data to prevent, detect, and combat fraud or unsafe activities.
  • To administer and protect our business and this App including troubleshooting, data analysis, monitoring trends so we can improve the App and system testing. Again, this is necessary for our legitimate interests.
  • We are obliged to regularly report your activities to third parties such as local councils or quangos such TFL.
  • Where we need to comply with a legal or regulatory obligation. This involves maintaining accurate financial data and when necessary liaising with law enforcement and Government bodies such as HMRC.

Disclosures of your personal data

We may work with reputable third-party payroll providers on whom we will have conducted due diligence regarding how they handle privacy.

We from time to time may share your personal data with the third parties. This will be done in accordance with the purpose for which we process your personal data. The third parties may include any company to which we outsource our services or collaborate with.

We will transfer your personal data to Dex Consulting (Development Partner) in India on the strict understanding that Dex Consulting (Development Partner) follow the same rules when processing your personal data. We use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

Data security

All information you provide to us is stored on our secure servers. Any payment transactions carried out by us or our chosen third-party provider of payment processing services will be encrypted using 256-bit encryption. Where we have given you (or where you have chosen) a password that enables you to access certain parts of the App Site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Once we have received your information, we will use strict procedures and security features to try to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way.

We will collect and store personal data on your Device using application data caches *. 

Data retention

By law we have to keep basic information about those who provide services to us for six years after they cease their involvement for tax purposes.

If you enquire about working with us then unless we reject your application then we will retain your personal data for six months. If you do not provide services and we delete your application then we will delete all your personal data. If we do not complete the registration, we will delete the personal data within one month of your application. 

Your legal rights

Under certain circumstances you have the following rights under data protection laws in relation to your personal data.

  • 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 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 data we hold about you corrected, though we may need to verify the accuracy of the new data 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 continuing 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:

if you want us to establish the data’s accuracy;

where our use of the data is unlawful but you do not want us to erase it;

where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or

you have objected to our use of your data 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 products or services to you. We will advise you if this is the case at the time you withdraw your consent.

COOKIES POLICY

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site.

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.

We use the following cookies:

  • Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
  • Analytical or performance cookies. These allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
  • Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences.
  • Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

You can find more information about the individual cookies we use and the purposes for which we use them in the table below:

Cookie Title

Cookie Name

Purpose
COOKIE TITLE

COOKIE NAME

DESCRIPTION OF THE PURPOSE FOR WHICH THE COOKIE IS USED AND ITS DURATION

Examples of purposes for which a cookie may be used:

This cookie is essential for our site to OR enables us to:

(a) Estimate our audience size and usage pattern.

(b) Store information about your preferences, and so allow us to customise our site and to provide you with offers that are targeted to your individual interests.

(c) Speed up your searches.

(d) Recognise you when you return to our site.

(e) Allow you to use our site in a way that makes your browsing experience more convenient, for example, by allowing you to store items in an electronic shopping basket between visits. If you register with us or complete our online forms, we will use cookies to remember your details during your current visit, and any future visits provided the cookie was not deleted in the interim.

etc

Please note that the following third parties may also use cookies, over which we have no control. These named third parties may include, for example, advertising networks and providers of external services like web traffic analysis services. These third-party cookies are likely to be analytical cookies or performance cookies or targeting cookies:

None at the present.

To deactivate the use of third-party advertising cookies, you may visit the consumer page to manage the use of these types of cookies [include link to consent management solution.

You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our website.

Except for essential cookies, all cookies will expire after 1 week.