CMT UK This Privacy Notice (together with our website terms of use and any other documents referred to on it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. For the purpose of the UK General Data Protection Regulation, tailored by the Data Protection Act 2018 (the “Act”), the data controller is CREATIVE MOBILE TECHNOLOGIES (UK) LIMITED Unit 11 Kendall Avenue, Vision Industrial Park, W3 0AF (“CMT UK”).
1. APPLICABLE USERS
This Privacy Notice applies to the following persons and entities: (a) visitors to our website(s) and application(s), and (b) persons and entities who provide information to CMT UK in connection with an application to use any products or services, or whose information CMT UK otherwise receives in connection with its products or services of CMT UK. These include any persons or entities who are: (a) users of CMT UK products and services who request or receive transportation services; and (b) users of CMT UK products or services who provide transportation services to any passenger. All are collectively referred to as “users” for purposes of this notice.
2. SCOPE OF NOTICE
The Privacy Notice applies to personal data we collect from any use or access of our "online" services, such as our websites, mobile applications, transportation booking and payment platforms, web and mobile services and platforms, and associated product solutions, however accessed or used (whether via personal computers, mobile devices, in-vehicle equipment or otherwise), or otherwise through any other channels, products or other services which we provide to you or in relation to any activities owned, operated, provided or made available by CMT UK in connection with its products and services (collectively, the "Services"). Please read this Privacy Notice carefully to understand our policies and practices regarding your information and how we will treat it. By visiting our website or accessing or using our Services, you agree to this Privacy Notice. If you have questions about this Privacy Notice, please contact us at uksupport@cmtgroup.com.
3. DATA COLLECTED
Data Provided. This may include:
· Account and Contact Information: You provide CMT UK with certain categories of information, which we may collect this information through various forms and in various places through the Services, including account registration forms, contact forms or when you otherwise interact with us. Such information includes personal information that could reasonably be used to identify you personally (collectively, "Personal Information"). Account and Contact information includes your first and last name, phone number, email, address, user name and password and birth date. This may also include the preferences and settings that you enable for you to access one or more accounts with CMT UK.
· Driver Information: We collect vehicle or insurance information of drivers, as well as your Transport for London (“TFL”) licence number, and background check information if you sign up to use CMT UK Services as a driver. This includes your driver history (where permitted by law). We also collect your driver’s licence and registration information as required by law.
· Demographic Data: We collect demographic information about you, including through user surveys. This includes age range and gender (for example, if your name is female coded, we may infer you are female for analytics purposes).
· User Profiles and Accounts: When you sign up to use the Services, you are required to create a user profile. The current data fields which you are required to complete in order to access the Services are your e-mail, password, name, mobile phone number, post code, and credit card number, expiration date, security code, or other digital payment accounts. If you choose to upload a photo when registering for our Services, the photo may be viewable by us and by the drivers who are picking you up so that they are able to verify your identity. You may remove or update the photo at any time by logging into your account.
· Financial Information. We collect your financial account information to pay you if you are a driver. This includes your account information, bank, address, and any other information necessary to provide a payment to you. If you are a rider using our transportation services, we collect and process the financial account information you provide to us using a third-party payment provider in order to process your transaction. This information is stored and managed by our third-party payment provider and includes account information, address, postal code, security code, transaction identifier, and amount.
Data Created When You Access And Use Our Services. This includes:
· Usage Data:We may collect data concerning your access and use of the Services ("Usage Information"), such as the browser that you are using, the URL that referred you to our Services, traffic data, logs and other communication data, the time of day, areas within our Services that you visit, and the resources that you access and use on or through the Services. In some cases, we collect this information through cookies, pixel tags, and similar technologies that create and maintain unique identifiers.
· Geolocation Data. Geolocation data is used for you to be able to view the drivers in your area that are close to your location, for you to set your pick up location . If you are traveling in a vehicle requested via our Services, geolocation data will be collected from the driver during your trip, even if you have not enabled your own mobile device or Mobile Applicable to collect your geolocation information. If you are a driver, we track your GPS location in order to manage our services and dispatch you to a rider upon request.
· Device data: We collect information about the devices you use to access the Services, including the hardware models, operating systems and versions, software, file names and versions, preferred languages, advertising identifiers, serial numbers, device motion information, mobile network information, device IP address or other unique identifier ("Device Identifier").
· Transaction data: We collect transaction details related to your use of the Services, including the type of services you requested or provided, your order details, date and time the service was provided, amount charged, distance traveled, and payment method. Additionally, if someone uses a promotion code we provide or may provide to you in future, we may associate your name with that promotion.
· Communications data: Certain Services enable users to communicate with each other and/or CMT UK. To provide this service, CMT UK receives some information regarding the calls or texts, (including the date, time and content of the call or text). CMT UK uses this information for customer support services (including to resolve disputes between users, payment disputes, or chargebacks), for safety and security purposes, to improve our products and services, and for analytics. This information may be collected by a vendor on CMT UK’s behalf. who is required to comply with the rules of the Act in the collection, handling and use of your Personal Information.
Data Third Parties Provide About You. We may, from time to time, supplement the information we collect about you through our web site or Device with outside records from third party persons or entities (“Third Parties”) in order to enhance our ability to serve you, to tailor our content to you and to offer you opportunities to acquire products or services that we believe may be of interest to you. We may combine the information we receive from those sources with information we collect through the Services. In those cases, we will apply this Privacy Policy to any Personal Information received, unless we have disclosed otherwise.
Data Permissible for Collection Through Specific Technologies. Several technologies are or may be used for automatic information collection, including:
· CMT UK uses cookies and other identification technologies on our CMT UK Mobile Application, our websites and emails for purposes described in this notice. Cookies are small text files that are stored on browsers or devices by websites, apps, online media, and advertisements. CMT UK uses cookies and similar technologies for purposes such as remembering preferences, authenticating users, analyzing application and website traffic and trends and to provide our services and ensure they work properly. We may also allow third parties to provide analytics services for us. These entities may use cookies, web beacons and other technologies to identify the devices used by visitors to our websites as well as when they visit other online sites and services. We do not merge the information collected through the analytics software or any web beacons to your Personal Information.
You have the right to choose whether or not to accept cookies. If you do not want information to be collected through the use of cookies, your browser or mobile settings allow you to deny or accept the use of cookies. Cookies can be disabled or controlled by setting a preference within your web browser or on your Device (including interacting with our cookie banners and preference center). However, as cookies are an important part of how our services work, if you choose to disable cookies on your Device, some features of the Services may not function properly or may not be able to customize the delivery of information to you; you may also experience difficulty accessing certain Services.
· Web Beacons. The web beacons are tiny graphic images or other web programming code with a unique identifier, similar in function to cookies, and are used to track the online movements of Web users. Web beacons (also known as clear gifs, pixel tags, single-pixel gifs or 1x1 GIFs) may be included in our web and mobile pages and messages. In contrast to cookies, which are stored in a user's Device hard drive, web beacons are embedded invisibly on Web pages. The purpose of web beacons or similar technologies is to help us better manage content on our Services by informing us what content is effective, and by helping us to count users of the Services, monitor how users navigate the Services, count how many e-mails that we send were actually opened, count how many particular articles or links were actually viewed, and for other related app statistics (for example, verifying system and server integrity and recording the popularity of certain app content). We do not tie the information gathered by web beacons to your Personal Information.
· Embedded Scripts. An embedded script is programming code the purpose of which is to collect information about your interactions with the Services, such as the links you click on. This programming code is temporarily downloaded onto your Device from our web server or a third party service provider, and is deactivated or deleted when you are no longer connected with the Services.
4. HOW WE USE THE DATA COLLECTED
Provide Services and Features. CMT UK uses the information we collect to provide, personalize, maintain and improve our products and services. This includes using the information to:
· Create, maintain and update your account, including verifying your information is active and valid.
· Verify your identity.
· Enable features to personalize your CMT UK account, and to allow you to view your trip history.
· Enable transportation and other services. This may include automated processing of your information to enable dynamic pricing, in which the price of a ride is determined based on constantly varying factors such as the estimated time and distance of the predicted route, estimated traffic, and/or the number of riders and drivers using CMT UK at a given moment and/or of drivers available on the CMT UK platform.
· Enable you to be matched with a driver/rider. CMT UK provides some of your Personal Information (such as your first name and your photo, if you have chosen to upload your photo to your profile) to the driver/partner who accepts your request for transportation so that the driver may contact and find you and (to the extent such a feature is available) to other users with whom you have consented to split the fare with for a particular trip. If you have accepted a request for transportation CMT UK provides the rider your first name, license plate, taxi license and vehicle description in addition to the geolocation of your vehicle during such trip.
· Process, facilitate, manage and distribute payments for those services (including to enable users to make payments for transportation services provided and to drivers to receive earnings).
· To track and share the progress of your ride.
· Perform internal operations necessary to provide our services, systems and tools, including to troubleshoot software bugs and operational problems, to conduct data analysis, testing, and research, to monitor and analyze usage and activity trends, and to manage payment claims and matters (including chargeback claims).
CMT UK performs the above activities on the grounds that they are necessary to fulfill the terms of its contracts with you as a rider or driver and on that the grounds that they are necessary for CMT UK’s legitimate interest.
Safety and Security. We use your information to help maintain the safety, security and integrity of our services and users. This includes, for example:
· Screening drivers prior to enabling their use of our services to ensure they are duly licensed drivers.
· Using device, location, profile, usage and/or other information to prevent, detect, and combat fraud, malicious activity, or other unsafe activities.
· Comply with and enforce applicable legal requirements, relevant industry standards and our policies.
· Prevent, discover and investigate violations of this Privacy Notice or any applicable terms and conditions or terms of use for our services.
· Using user ratings, feedback, and communications made known to CMT UK to encourage improvement by affected users, and as grounds for deactivating users with ratings below a certain minimum as may be required, or who present safety or security concerns based on past conduct.
CMT UK performs the above activities on the grounds that they are necessary to fulfill the terms of its contracts with you as a rider or driver and on that the grounds that they are necessary for CMT UK’s legitimate interest and for the safety and security of our users and the public.
Customer Support. CMT UK uses the information we collect to assist you when you contact our customer support services, including to investigate and address your concerns, and monitor or improve our customer support responses.
CMT UK performs the above activities on the grounds that they are necessary to fulfill the terms of its contracts with you as a rider or driver and on that the grounds that they are necessary for CMT UK’s legitimate interest and for the safety and security of our users and the public.
Research and development. We use the information we collect to carry out statistical analyses relating to our business, services, systems and tools (including anonymization and aggregation of personal information for data analysis) and for testing, research, analysis and product development. This allows us to improve and enhance the safety and security of our services, develop new features and products.
CMT UK performs the above activities on the grounds that they are necessary for CMT UK’s legitimate interests in improving and developing new features and services.
Communications among users. CMT UK uses the information we collect to enable communications between our riders and drivers. This is the case where, for example, a driver or CMT UK dispatch center texts or calls a rider to confirm a pickup location or help a driver reach a passenger pick-up location.
CMT UK performs the above activities on the grounds that they are necessary to fulfill the terms of its contracts with riders and drivers.
Communications from CMT UK. CMT UK uses the information we collect to
· communicate with you about products, services, promotions, updates, events, studies, surveys or news.
· generate and provide users with receipts; inform them of changes to our terms, services or policies; or send other communications that are not for the purpose of marketing the services of CMT UK or its partners.
CMT UK performs the above activities on the grounds that they are necessary to fulfill the terms of its contracts with riders and drivers and that they are necessary for CMT UK’s legitimate interests informing users on new features and services.
Legal proceedings and requirements. We use the information we collect to investigate or address claims or disputes relating to your use of CMT UK’s services, or as otherwise allowed by applicable law, or as requested by regulators, government entities, and official inquiries. We may also use the information we collect to investigate or address claims or disputes relating to your use of CMT UK’s services, or to the services provided by our payment and security vendors and partners, to manage, prosecute, defend, manage or resolve security, data or payment claims (including, for example, chargeback claims).
CMT UK performs the above activities on that the grounds that they are necessary for CMT UK’s legitimate interest, for the safety and security of our users and the public and for compliance with applicable legal requirements.
Marketing and Advertising. We use the information we collect to market the services and allow you to view any promotions we may currently be running and which may include sending emails, text messages, push notifications and in-app messages or other communications marketing CMT UK Services.
CMT UK performs the above activities on the grounds that they are necessary for CMT UK’s legitimate interests informing users on new features and services or based on your consent (for example, if you sign up for a newsletter, accept cookies, or enable marketing features in our applications). Where we rely on your consent, you may withdraw that consent at any time by contacting us.
5. HOW WE COMMUNICATE WITH YOU
Based upon the Personal Information you provide us when registering for an account, we will send you a welcoming email to verify your username and password. We will also communicate with you in response to your inquiries, to provide the services you request, and to manage your account. We may communicate with you by email, telephone or SMS or text message, in accordance with your wishes. Please note that information submitted to the Services via a "contact us" or other similar function may not receive a response.
We will send you strictly service-related announcements on rare occasions when it is necessary to do so. For instance, if our Services are temporarily suspended for maintenance, we might send you an email. Generally, you may not opt-out of these communications, which are not promotional in nature. If you do not wish to receive them, you have the option to deactivate your account.
6. DATA SHARING
We may disclose personal information that we collect or you provide: (a) to the subsidiaries and affiliates of the CMT UK, (b) to comply with any court order, law or legal process, including to respond to any government or regulatory request, contractors, service providers and other third parties we use to support our business, (c) if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the CMK UK and its customers or others (this includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction), (d) to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of the assets of the CMK UK, whether going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by the CMK UK about its use among the assets transferred, (e) to enforce our rights arising from any contracts entered into between you and us, including without limitation the Terms and Conditions, and for billing and collection, (f) for any provider of payment, technology and/or transit services associated with the Services, (g) for any other purpose disclosed by us when you provide the information, and/or (i) with your consent.
CMT UK provides some of your Personal Information (such as your first name and your photo, if you have chosen to upload your photo to your profile) to the driver/partner who accepts your request for transportation so that the driver may contact and find you and (to the extent such a feature is available) to other users with whom you have consented to split the fare with for a particular trip.
We do not sell, share, rent or trade the information we have collected about you, including Personal Information, other than as disclosed within this Privacy Notice or at the time you provide your information. We do not share your Personal Information with Third Parties for those Third Parties' direct marketing purposes unless you consent to such sharing at the time you provide your Personal Information. We may share non-personally identifiable information (for example, aggregated user statistics and log data) with Third Parties for business purposes.
Consent to Share Data with Third Parties. If you agree to accept requests for transportation that originate from third party rideshare partners of CMT UK, then you consent to CMT UK sharing your name, license plate, taxi license and vehicle description in addition to the geolocation of your vehicle during such trip.
Administrative and Legal Reasons.
We cooperate with government and law enforcement officials and private parties to enforce and comply with the law. Thus, we may access, use, preserve, transfer and disclose your information (including Personal Information), including disclosure to third parties such as government or law enforcement officials or private parties as we reasonably determine is necessary and appropriate to:
· Satisfy any applicable law, regulation, subpoenas, governmental requests or legal process,
protect and/or defend the Terms and Conditions for online and mobile Services or other policies applicable to any online and mobile Services, including investigation of potential violations thereof,
· protect the safety, rights, property or security of the CMT UK, our Services or any Third Party,
· detect, prevent or otherwise address fraud, security or technical issues, and/or
· prevent or stop activity we may consider to be, or to pose a risk of being, an illegal, unethical, or legally actionable activity.
Third Party Service Providers. We use Third Parties to facilitate our Services, provide or perform certain aspects of the Services on our behalf (including Bank of America, American Express and Elavon for payment services, and ARRO Inc., for certain trip management services). We may provide these Third Parties with access to user information, including Personal Information, provided this information sharing shall be limited to only the information needed by the Third Parties to carry out the services they are performing for you or for us. Each of these Third Parties are obligated not to disclose or use Personal Information for any other purpose. When we may use third party analytics service providers to evaluate and provide us with information about the use of the Services and viewing of our content, they may set and access their own cookies, web beacons and embedded scripts on your Device and they may otherwise collect or have access to information about you, including non-personally identifiable information. We use a third-party hosting provider who hosts our support section of our website. Information collected within this section of our web site is governed by our Privacy Notice.
Content of and Links to Third Parties. Our Services (including any website or Mobile Application) may provide links to other websites and applications for your convenience and information. These websites and applications may operate independently from us. Linked sites and applications may have their own privacy notices or policies, which we strongly suggest you review. These other web sites may send their own cookies to you, independently collect data or solicit Personal Information and may or may not have their own published privacy policies. We encourage you to note when you leave our Services and to read the privacy statements of all third-party web sites or applications before submitting any Personal Information to third parties. To the extent any linked websites or applications are not owned or controlled by us, we are not responsible for the sites’ or applications’ content, any use of the sites or applications, or the privacy practices of the sites or applications.
7. INFORMATION YOU DISCLOSE PUBLICLY
User Generated Content and Public Information. The Services may offer publicly accessible blogs or community forums or other ways to permit you to submit ideas, photographs, user profiles, writings, music, video, audio recordings, computer graphics, pictures, data, questions, comments, suggestions or other content, including Personal Information (collectively, "User Content"). We may reproduce, publish, distribute or otherwise use User Content online or offline in any media or format (currently existing or hereafter developed). This can include, for example, reproduction of User Content on passenger information monitors (PIMs) in taxis equipped with this or analogous solutions. Additionally, others may have access to this User Content to the extent it is displayed or broadcast on any one or more publicly accessible media (such as, for example, any website forum or PIM display), and may have the ability to reproduce, use or otherwise share it with third parties across the Internet. You should be aware that any User Content you provide in these areas may be read, collected, and used by others who access them. We may also publish your name, voice, likeness and other Personal Information that is part of your User Content, and we may use the content, or any portion of the content, for advertising, marketing, publicity and promotional activities. Thus, please think carefully before deciding what information you share, including Personal Information, in connection with your User Content. Please note that CMT UK does not control who will have access to the information that you choose to make public and cannot ensure that parties who have access to such publicly available information will respect your privacy or keep it secure.
8. SOCIAL MEDIA FEATURES AND WIDGETS
Our online and mobile Services may include social media features, such as the Facebook Like button, and widgets such as a sharing or re-post button, or interactive mini-programs that run on our online and mobile Services. These features may collect your IP address, which page you are visiting on our online or mobile Services and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a Third Party or hosted directly on our online Services. Your interactions with these features and widgets are governed by the Privacy Notice of the social media service providing them.
9. YOUR RIGHTS
User Rights. You have the following rights with respect to CMT UK’s handling of your personal information. To exercise these rights, please see below or submit your request at uksupport@cmtgroup.com.
· Access. Explanation and copies of your data. You have the right to request an explanation of the information that CMT UK has about you and how CMT UK uses that information.
· Portability. You also have the right to receive a copy of the information that CMT UK collects about you if collected on the basis of consent or because CMT UK requires the information to provide the services that you request.
· Correction. If CMT UK has information about you that you believe is inaccurate, you have the right to request correction of your information. You are responsible for maintaining the accuracy of the information you submit to us at all times, such as your contact information provided as part of account registration. If your Personal Information changes, or if you no longer desire our Services, you may correct, delete inaccuracies, or amend information by making the change on our member information page or by contacting us through uksupport@cmtgroup.com.
· Deletion. Users may request deletion of their accounts at any time. Users may request deletion through the Privacy Settings menu in the CMT UK app, or via CMT UK’s website. We may retain certain information about you as required by law and for legitimate business purposes permitted by law. Please see the “Information Retention & Deletion” section above for more information regarding CMT UK’s retention and deletion practices.
· Objection and complaints. Users the right to object to CMT UK’s processing of personal data, including for marketing purposes based on profiling and/or automated decision making. CMT UK may continue to process your information notwithstanding the objection to the extent permitted under the Act. You may also submit questions, comments or complaints to CMT UK’s Data Protection Officer here uksupport@cmtgroup.com.
You may also cancel or modify your communications that you have elected to receive from the Services by following the instructions contained within an e-mail or by logging into your user account and changing your communication preferences. If you wish to cancel your account or request that we no longer use your information to provide you services, contact us through uksupport@cmtgroup.com.
10. CHILDREN
CMT UK cares about the safety of children. Because our Services are not directed toward minors, no one under 18 is allowed to register for use of the Services. We do not knowingly collect Personal Information from anyone under the age of 18. If we discover that we have collected Personal Information from a person under 18, we will delete that information immediately. If you are a parent or guardian of a minor under the age of eighteen (18) and believe he or she has disclosed Personal Information to us, please contact us at legal@cmtgroup.com.
11. SECURITY OF DATA
The credit card information you provide in your personal profile at sign-up is not stored by CMT UK but is stored and used by our third-party credit card processors in order for them to process payment for transportation services received by you. The Personal Information and Usage Information we collect is securely stored within our databases, and we use standard, industry-wide, commercially reasonable security practices such as encryption, firewalls and SSL (Secure Socket Layers) for protecting your information - such as any portions of your credit card number which we retain (we do not ourselves retain your entire credit card information) and geolocation information. We require that you not disclose your password to anyone.
13. STORAGE AND RETENTION OF PERSONAL INFORMATION
We will store and retain your Personal Information for as long as is reasonably necessary for the purposes for which it was collected and in line with our respective data retention policies.
Even after your account is terminated, we may retain your Personal Information and Usage Information (including geolocation, trip history, credit card information and transaction history) as needed to comply with our own or our affiliates’ legal and regulatory obligations, resolve disputes, conclude any activities related to cancellation of an account (such as addressing chargebacks from your credit card companies), investigate or prevent fraud and other inappropriate activity, to enforce our agreements, and for other legally permissible grounds pursuant to GDPR.
14. INTERNATIONAL TRANSFER
Your Personal Information is primarily processed within the UK but we may transfer Personal Information from the UK to the United States and to other countries, including Personal Information we receive from individuals residing in the UK who use our Services or otherwise interact with us. Please note that the term Personal Information used in this notice is equivalent to the term “personal data” under applicable UK data protection laws.
When we engage in such transfers of Personal Information, it relies on i) Adequacy Decisions as adopted by Information Commissioner’s Office on the basis of the Act, or ii) Standard Contractual Clauses issued by the Information Commissioner's Office. We also continually monitor the circumstances surrounding such transfers in order to ensure that these maintain, in practice, a level of protection that is essentially equivalent to the one guaranteed by the UK GDPR.
15. EXPLANATIONS, COPIES AND CORRECTION
You may request that CMT UK
· Provide an explanation regarding the information CMT UK has collected about you and how it uses that information.
· Make available a copy of the information CMT UK has collected about you.
· Make a correction of any inaccurate information that CMT UK has about you, which you can provide in supporting written documentation.
You can make these requests by contacting CMT UK at uksupport@cmtgroup.com. You can also edit the name, phone number and email address associated with your account through the Settings menu in CMT UK’s apps. You can also look up your trips, orders and deliveries history in the CMT UK apps.
16. MARKETING OPT-OUTS
You may opt out of receiving promotional emails from CMT UK at uksupport@cmtgroup.com. You may also opt out of receiving emails and other messages from CMT UK by following the instructions in those messages. Please note that if you opt out, we may still send you non-promotional messages, such as receipts for your rides or information about your account.
17. UPDATES TO THIS NOTICE
We may occasionally update this Notice. If we make significant changes, we will notify you of the changes through the CMT UK apps or through others means, such as email. To the extent permitted under applicable law, by using our Services after such notice, you consent to our updates to this Notice. We encourage you to periodically review this Notice for the latest information on our privacy practices.
18. DATA PROTECTION OFFICER
CMT UK has appointed a data protection officer to manage its compliance with the Act. You may contact the Data Protection Officer at:
CMT UK Data Protection Officer
Address: CREATIVE MOBILE TECHNOLOGIES (UK) LIMITED, Unit 11 Kendall Avenue, Vision Industrial Park, W3 0AF, Attention; Data Protection Officer
