Last Updated: October 31, 2019
1.1 Gett (“Gett”, “we”, “our”, and/or “us”) is a company committed to protecting and respecting the privacy of all persons contacting, visiting, or otherwise submitting information to Gett.
1.2.1 use a Gett website and/or Gett B2B portal (together the “Site”);
1.2.2 use a Gett kiosk; and/or
1.2.3 download or use one of the Gett Mobile Telephone Applications (“App”).
1.3 You Personal Information is collected by us whether you are:
1.3.1 a driver and/or courier (in each case, a “Driver”);
1.3.2 a rider, delivery recipient and/or sender (in each case, a “Rider”);
1.3.3 App user;
1.3.4 Site visitor;
1.3.5 office visitor; and/or
1.3.6 job applicant.
- USER’S ACKNOWLEDGEMENT OF THIS POLICY
If you have any questions or comments regarding privacy issues on the Site and/or the App, please contact Gett by email at email@example.com
- TYPES OF INFORMATION WE COLLECT
3.1.1 Gett collects both “Personal Information” and “Anonymous Information” about our users and visitors. Personal Information is information that can be used to identify you, such as your full name, email address, phone number, payment method, login name, password, mailing address, IP address, and profile picture, location, as well as information that is linked to such information. “Anonymous Information” is information that we cannot use to identify you and is not linked to information that can be used to do so. It includes passively collected information about your activities on the Site or on the App, such as use and usage data, to the extent that information is not linked to your Personal Information.
3.1.2 While accessing certain portions of the Site and the App, we passively collect certain information from your devices, such as your IP address, screen resolution information, geographic location, Wifi information, browser information, unique device identifier (“UDID”) where applicable and/or your mobile operating system, and use third party service providers to obtain detailed analytics. We also collect geolocation data from visitors that download and open the App. Sometimes, this passively collected information will constitute Personal Information – please see Sections 3.1.4 and 3.1.5 in particular.
3.1.3 Voluntarily submitted information.
We collect information that you provide to us during your use of the Site and/or the App. Some examples include:
126.96.36.199 Personal Information that you enter when registering for or using the App, including your full name, email address, phone number, payment method, billing information, profile picture and profile information. The provision of some of this information (as indicated by us) is mandatory in order to create an account and use our services;
188.8.131.52 communications with us (e.g. emails, in-app messages and photos, text messages) or with Drivers (e.g. written in-app instructions to Drivers);
184.108.40.206 user preference information you provide such as marketing preferences, communication preferences (e.g. sms or in-app messages) home address, work address, and/or favourites, as well as information in surveys;
220.127.116.11 information you provide to our customer support team or other Gett staff by email, post, the App, sms, Facebook messenger, in-app messaging, telephone or otherwise, in which case Gett may keep a record of that correspondence to respond to your enquiries and improve its services, and we may record your customer support calls for quality assurance purposes and for improving our services. Any photos you send us will be stored on your own device;
18.104.22.168 information that you post on any forums or message boards (such as Gett’s blogs, Gett’s pages on third party social media sites, and other third party maintained and publicly accessible forums where Gett is discussed);
22.214.171.124 data you provide, including photos or comments, in connection with or participation in any promotions or competitions sponsored, promoted or offered by Gett and/or any third-party and any data provided to Gett by way of feedback, profile forms or Site/App issues;
126.96.36.199 data you provide, including a copy of your identification or credit card, in connection with special instances relating to fraud or otherwise where Gett needs to authenticate user identity and/or ownership of the payment method provided. Full credit card information is not retained by Gett, and the copy of your credit card will be used solely for the purposes of authenticating your ownership and preventing fraud;
188.8.131.52 where you are a Driver, insurance policies, fleet information, vehicle information, and licensing information. This provisions of this information is mandatory in order to become a Driver; and
3.1.4 Information collected through use of the Site or the App
184.108.40.206 Geolocation data: If you access the App through a mobile device, we may access, collect, monitor and/or remotely store “geolocation data,” which may include the GPS coordinates of your trip (including pickup and drop-off data and route information) or similar information regarding the location of your mobile device.
220.127.116.11 Contacts: We may access your calendar or contacts if you provide us with your permission to do so.
18.104.22.168 Transaction data: We collect information created during your various interactions with the Service, including the date and time of an order, Driver acceptance of the order, Driver arrival, completion of the Services, as well as distance travelled, amount charged, including breakdown of base fee, tip and additional fees, as well as promotional code delivery.
3.1.5 Information collected via technology
22.214.171.124 In connection with your use of the App, we may receive the date and time of calls, SMS and in-app messages with Gett and their respective content, as well as a record of the fact that you contacted a Rider or Driver . For the avoidance of doubt, Gett does not have access to the content of calls and/or SMS messages between Riders and Drivers, or any information whatsoever about your calls or SMS messages to any third-parties (i.e. anyone other than Gett or a Driver / Rider).
126.96.36.199 We may use third-party services with your use of the App, such as Google Analytics and Mixpanel to track and analyse trends and patterns in relation to consumer behaviour .
188.8.131.52 We may also use third-party fraud prevention services to track and analyse Rider and Driver usage logs, device logs, root logs, screen logs, and granted permission logs for purposes of security, fraud prevention, and money laundering prevention.
184.108.40.206 If you choose to download or login to the App or Site via a third-party website, your Personal Information may be provided to us by that website.
220.127.116.11 Because we rely on third-party commercial software and programs to operate our servers, we may inadvertently collect Personal Information due to certain automatic functions or features contained in such software or due to certain software changes or upgrades. We will use reasonable efforts to remove any such information prior to engagement and after discovery in our system. If you know of any such unintended collections, please notify us promptly so we can take the necessary action to remove such information from our system.
3.1.6 Information provided by others
We collect information that Riders provide about Drivers, and vice-versa, including ratings, complaints, and postings on Gett’s forums or message boards, or those of third parties (such as news media) where Gett is discussed.
Gett may receive information about you if you use any of the other websites or other services its affiliates provide. Gett also works closely with third parties (including, for example, business partners, subcontractors in technical, payment, delivery and transportation services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about you from them. Where third-parties collect information about you and share it with us, you should refer to their separately maintained privacy policies or notices.
3.1.7 Information about your device
18.104.22.168 Gett collects information about the device you use to access the Site, App and/or Services, which may include personal data. This information is used to recognise your device so that it can be linked to your account. This activity is carried out for purposes of safety, security, evaluation of the performance of the App or the Site, improvement and optimization of the customer experience, fraud prevention and may involve the sharing of information about your device including limited personal data, IP address, WiFi and location information with a third-party service provider.
22.214.171.124 Gett collects information about installed malicious applications that are specifically used to commit fraud against Gett (“Installed Apps”), including the Installed Apps’ name and installation date. For the avoidance of doubt, we do not collect data within the Installed Apps;
126.96.36.199 the battery and network performance (i.e. battery status and charger use) of your device and the file names, types and files sizes on your device, including the amount of free and used local storage space, but not the contents of the files; and
188.8.131.52 the system status, including device event information such as crashes and system activity.
- COOKIES AND OTHER WEB FILES OR TAGS
- USES MADE OF THE INFORMATION
|To register, authenticate, and administer your account||The performance of a contract with you (or steps taken at your request prior to entering into a contract)
Our legitimate interest in ensuring the security of your account through user authentication
|To provide our various Services, as further detailed on our Site||The performance of a contract with you (or steps taken at your request prior to entering into a contract)|
|To accept and process payments including, for Drivers, negotiating or concluding the sale of your services on your behalf||The performance of a contract with you (or steps taken at your request prior to entering into a contract)|
|To facilitate communications between Riders and Drivers||The performance of a contract with you (or steps taken at your request prior to entering into a contract)|
|To offer customer support|
|To improve and optimise the Site and/or the App including tailoring it to your needs, including by ensuring that content on the Site and/or the App is presented in an effective manner for you and for your device (e.g. PC, mobile telephone, tablet)||Our legitimate interest in optimising the presentation of our Services and tailoring them to our user’s environment|
Our legitimate interest in communicating important updates to you regarding the Services you have contracted for, or our legal notices
|To validate and reimburse valid third-party loyalty coupons for Gett Services and to notify third-party loyalty partners about qualifying Services which may accrue third- party loyalty scheme points||Our legitimate interest in participating in loyal schemes run by third parties.|
|To provide you with information (by email, sms, messenger, post or telephone) about other goods and services Gett offers that are similar to those that you have already purchased or enquired about or which may interest you, having first obtained your consent where required to do so (and subject always to your right to opt-out of marketing messages, see section 11.1.4)||Consent
Our legitimate interest in promoting our products and Services, subject to providing you with the ability to opt-out of marketing when your details are first collected
|To contact you for your views on Gett’s Services||Our legitimate interest in carrying our surveys into user opinions of our Services, so that we can make improvements to the Services|
|For our own data analysis, testing, research, statistical purposes, including using deep learning, machine learning and/or artificial intelligence, in order to innovate and improve our Services.||Our legitimate interest in harnessing data collected as part of our Services in order to gain insights into how those Services are used, to drive product and service improvement.|
|Gett’s efforts to keep the Site and the App safe and secure and for the prevention of fraud||Compliance with a legal obligation where anti-fraud or money laundering checks are required by law.|
|Statistical analysis of the demographic profile of our users on an aggregated basis – Gett may provide Personal Information to third party service providers who provide the demographic analysis, and provide Gett with non-personal statistical information.||Our legitimate interest in understanding our user base so that we can better tailor and improve our Services.|
|To measure or understand the effectiveness of any advertising Gett serves to you.||Where cookies or similar technologies are required – your consent. Otherwise, our legitimate interest in understanding the success of our advertising campaigns.|
|To use GPS to identify the location of Riders and Drivers|
- SECURITY AND DATA RETENTION
6.1 Gett has implemented administrative, physical and electronic measures designed to protect your information from unauthorized access, modification and unavailability. Gett will comply with applicable law in the event of any breach of the security, confidentiality, or integrity of your Personal Information and, where we consider appropriate or where required by applicable law, notify you via email, text or conspicuous posting on the Site in the most expedient time possible and without unreasonable delay, insofar as it is consistent with (i) the legitimate needs of law enforcement or (ii) any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system.
6.3 Where Gett has given you (or where you have chosen) a username, login or password which enables you to access certain parts of the Site and/or the App, you are responsible for keeping this information confidential. Gett asks you not to share a username, login or password with anyone, and not to reuse the same password across multiple websites.
6.4 Gett restricts access to your Personal Information to individuals who need access to it in order to process it on Gett’s behalf. These individuals, where employees, are bound by confidentiality agreements and Gett will take appropriate action (which may include disciplinary proceedings) in the event Gett finds that its employee(s) has failed to meet standards in looking after your Personal Information. Gett cannot accept any liability for employees or agents acting outside the normal course of their employment or the terms of their agency agreement, or for Drivers or any third-parties with whom your Personal Information may be shared (as described in section 8) who act outside of the terms of our contracts with them.
6.5 We will retain your Personal Information only for as long as necessary to fulfil the purpose(s) for which it was collected and to comply with applicable laws.
6.6 In general, this means that we store your data throughout the existence of your account with us or for as long as is otherwise required to deliver our Services, except where we have a lawful basis for saving it for an extended period of time (for instance, after fully executing a contract, we may still have a legitimate interest in using your contact details for marketing purposes). We also retain the data we need for the execution of pending tasks and the data we need to investigate and realize your complaints or queries, or our legal rights and our claims, as well as certain data that we must store for a legally mandatory period of time. When certain data is only saved due to a legally mandatory preservation term, the processing of it by us is limited, even where you do not specifically request this.
- DISCLOSURE AND SHARING OF YOUR INFORMATION
7.3 In addition to using the information collected by us for the purposes described in section 6 above, we may also share your information as described below. Please review our sharing policy closely, especially with respect to your Personal Information.
7.4 Riders and Drivers
7.4.1 We share certain information about Riders (including but not limited to name, pickup and drop-off locations, route information, profile picture) with Drivers to enable the scheduling and provision of the Services.
7.4.2 We share certain information about Drivers (including but not limited to name, rating, location, profile picture, license plate number, fleet information, birthday week) with Riders to enable the scheduling, provision, and receipt of the Services.
7.4.3 Information provided on any online forum or message board (including those maintained by third parties) may be viewed by any Riders or Drivers who access the forum or board.
7.5 Service Providers
7.6 Compliance with Laws, Law Enforcement and Safety
We may disclose information we have collected about you if required to do so by law or if we, in our sole discretion, believe that disclosure is reasonable to comply with the law, requests or orders from law enforcement, or any legal process (whether or not such disclosure is required by applicable law), or to protect or defend Gett’s, or a third-party’s, rights or property. We may also reserve the right to disclose information we’ve collected about you for purposes of protecting the health and safety of our Riders and Drivers, such as in the case of risk of harm or violence against any person. Finally, we may also disclose information in order to enforce or apply our Terms and Conditions https://gett.com/uk/legal/terms/ and other agreements; or to protect the rights, property, or safety of Gett, its customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
7.7 Anonymous Information
Aggregated Anonymous Information is the combination of your Anonymous Information with the Anonymous Information of other users (“Aggregated Anonymous Information”). Aggregated Anonymous Information does not allow you to be identified or contacted. We may share such Aggregated Anonymous Information with third-parties to further the purposes described herein, or for other commercial purposes, in our sole discretion.
7.8 Within the Gett Group of Companies
7.9 Business Transactions
- LOCATION OF YOUR INFORMATION
8.1 Your Personal Information may be disclosed to Gett Group entities and third-parties (including service providers) in jurisdictions including, but not limited to: Cyprus, Israel, Ireland, Russia, United Kingdom, and the United States of America.
8.2 Consequently, the data that Gett collects from you may be transferred to, and stored in, a country that is not considered to offer an adequate level of protection under your local laws. It may also be processed by staff operating outside of your country of residence who work for Gett or for one of its suppliers, service providers or partner entities. By submitting your Personal Information, you acknowledge, and, where necessary under local laws, agree to, this transfer, storing or processing.
8.3 Gett may also make disclosures of your Personal Information to government entities, courts or regulators in other countries, where these are disclosures anticipated by section 8. In this context, we may rely on the fact that a disclosure to a court or administrative authority is based on an international agreement, which provides a legal basis for the transfer.
- JOB APPLICANTS
In submitting your application, your Personal Information included in your CV will be used as outlined in our Terms and Conditions for Job Applicants that you will find https://gett.com/uk/legal/terms-conditions-job-applicants/ . If you do not want your Personal Information to be used, please do not submit your CV.
- YOUR RIGHTS
10.1 Subject to applicable law, you may have some or all of the following rights in respect of your Personal Information:
10.1.1 Access to own Personal Information: You may also have the right to obtain a copy of the Personal Information held about you, and to be informed of certain details, such as (a) the source of your Personal Information; (b) the purposes, legal basis and methods of processing; (c) the data controller’s identity; and (d) the entities or categories of entities to whom your Personal Information may be transferred.
10.1.2 Accuracy and right of rectification: Gett seeks to ensure that your Personal Data is accurate, complete and kept up-to-date to the extent reasonably necessary for the purposes described herein. You also have the ability to update the information we hold about you through your Gett account. If the Personal Information is incorrect, incomplete or not processed in compliance with applicable law or this Policy, you may have the right to have your Personal Information rectified or deleted in accordance with applicable law.
10.1.3 Right to object: In certain circumstances (e.g., where your Personal Information is processed on the basis of Gett’s legitimate interests), you may have the right to object to the processing of your Personal Information on the basis of compelling grounds related to your particular situation and in accordance with applicable law.
10.1.4 Right to prevent direct marketing: You may have the right to request that Gett does not process your personal data for marketing purposes. In such a case, you can control your initial marketing preferences by ticking the relevant box situated within the App settings or an ‘unsubscribe’ link within a marketing email. Thereafter, you can follow the opt-out links or unsubscribe directions in emails or SMS messages.
10.1.5 Right to withdraw consent: If the processing of your Personal Information is based on your consent, you may have the right to withdraw your consent to such processing at any time. It is worth noting that the withdrawing of consent has no impact on earlier processing on such basis, and does not prevent Gett from invoking another legal basis for the processing of the relevant Personal Information.
10.1.6 Right to lodge a complaint: You may have the right to lodge a complaint before the relevant data protection authority or supervisory authority.
10.2 To exercise these rights, where applicable, please contact Gett at privacy@Gett.com or use the appropriate functionality in the App.
10.3 We may ask you for additional information to confirm your identity and for security purposes before complying with your request. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive.
10.4 Some rights may be subject to exemptions created by applicable law or may only be exercisable in certain circumstances. We will communicate openly with you to help you to understand whether, and to what extent, a right is exercisable. Subject to legal and other permissible considerations, we will make every reasonable effort to honour your request promptly or inform you if we require further information in order to fulfil your request.
- THIRD PARTY WEBSITES
11.1 From time to time Gett may post links to third-party websites on the Site and/or the App. These links are provided as a courtesy to Gett’s users and visitors and are not administered or verified in any way by Gett. Such links are accessed by you at your own risk and Gett makes no representations or warranties about the content of such websites including any cookies used by the website operator. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that Gett does not accept any responsibility or liability for these policies. As a result, Gett strongly recommends that you read the privacy policies of any third-party websites before you provide any personal data to them.
Neither the Site nor the App are directed or targeted to children under the age of 18, and Gett does not knowingly collect personally identifiable information from children under the age of 18. Gett requires users under 18 years of age to obtain the consent of a parent or guardian, to view the Site or use the App. If Gett learns that a child under 18 years of age has provided personally identifiable information to the Site, it will use reasonable efforts to remove such information from its files. No part of our Service is directed towards children under the age of 18 and we do not want Personal Information from children under the age of 18. If you believe that a child under 18 years of age has given us Personal Information, please contact Gett at firstname.lastname@example.org.
Gett has a Data Protection Officer responsible for monitoring Gett’s compliance with EU data protection laws. The Data Protection Officer can be contacted at email@example.com.
APPENDIX 1: RUSSIA
You hereby understand and agree, that in certain cases you may be additionally asked to sign written consent for data processing necessary to provide services in compliance with applicable legislation (e.g. under Russian Federal Law No. 152-FZ “On Personal Data” dated 27 July 2006). You hereby understand and acknowledge, that if personal data consent is not provided, it is likely that we will not be able to provide you with services.