Effective as of January 1, 2018
1.1 Gett (“Gett”, “we”, “our”, and/or “us”) is a company committed to protecting and respecting your privacy, as user or person contacting, visiting, or otherwise submitting information to Gett.
1.3 Gett is committed to safeguarding your Personal Information (as defined below) in line with applicable data protection laws. Please read the following carefully to understand Gett’s views and practices regarding your personal data and how Gett will treat it.
2. 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
3. TYPES OF INFORMATION WE COLLECT
3.1 Gett collects both “Personal Information” and “Anonymous Information” about our users and visitors. Personal Information is information that can be used to contact or identify you, such as your full name, email address, phone number, payment method details, login name, password, mailing address, IP address, and profile picture, as well as information that is linked to such information. “Anonymous Information” is information that we cannot use to contact or 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 usage data, to the extent that information is not linked to your Personal Information.
3.2 You can access and browse certain portions of the Site and download the App without disclosing Personal Information, although, like most website and mobile app providers, 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-parties such as Mixpanel and other SDK’s to obtain detailed analytics on the device. 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 3.1.5 and 3.1.7 in particular. Please note that you can choose not to provide us with certain information (for instance, by adjusting your cookie settings, see Section 5), and it is your voluntary decision whether to provide us with any such information but choosing not to will limit the features of the Site or the App you can access and use.
3.3 Voluntarily submitted information.
We collect information that you provide to us during your use of the Site, and/or App. Some examples include:
3.3.1 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;
3.3.2 communications with us (e.g. emails, text messages) or with other Riders or Drivers (e.g. verbal or written instructions to Drivers);
3.3.3 information you provide in your user preferences or surveys, to customer support services or customer support calls or that you post on any forums or message boards, including social media and blogs. We may record your customer support calls for quality assurance purposes and for improving our services;
3.3.4 the provision of services or online content to deal with your requests and enquiries. This includes data you provide at the time of: registering to use the Site and/or the App; subscribing to any services or Gett offers; downloading information posted on the Site and/or the App; posting material; or requesting further services from Gett;
3.3.5 data you provide to us or to a third-party in connection with third-party loyalty schemes with which Gett partners, including loyalty ID or scheme membership number and information about points accrued;
3.3.6 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;
3.3.7 data you provide, including a copy of your identification or credit card, in connection with instances where Gett needs to authenticate user identity and/or ownership of the payment method provided;
3.3.8 information about you which you provide when corresponding with Gett by email, post, the App, sms, messenger, telephone or otherwise, in which case Gett may keep a record of that correspondence to respond to your enquiries and improve its services;
3.3.9 where you are a Driver, insurance policies and licensing information; and
3.3.10 other information from your interaction with the Site and/or the App, services, content and advertising. With regard to each of your visits to the Site and/or use of the App, Gett may automatically collect authentication data, technical information and information about your visit, including computer and connection information, statistics on page views, traffic to and from the Site, ad data, IP address, standard web log information and the resources that you access.
3.4 Information collected through use of the Site or the App
3.4.1 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.
3.4.2 Contacts: We may access your address book, calendar, or contacts if you provide us with your permission to do so.
3.4.3 Transaction data: We collect information created during your various interactions with the Service, including the date and time of any ride using the Gett Service (a “Ride”), distance of Ride, amount charged, including breakdown of base fee, tip and additional fees, as well as promotional code delivery.
3.5 Information collected via technology
3.5.2 In connection with your use of the App, we may receive your call data, including the date and time of calls and SMS messages with Gett or Drivers, the parties’ phone numbers and the content of those SMS messages.
3.5.3 We may also use third-party tracking services, such as Google Analytics, and usage logs, to track and analyse data from users of the Service for purposes of security, fraud prevention, and money laundering prevention.
3.5.4 If you choose to remit payment for a Ride via a third-party payment provider (e.g. Google Wallet), your Personal Information (excluding full payment card information) obtained by the payment provider may be given to us by such payment provider.
3.5.5 If you choose to login to the App or Site via a third-party social media website (e.g. Facebook), your Personal Information may be provided to us by such social media website.
3.5.6 Gett may also share your data with its third-party statistical analytics service provider, solely for the provision of analytics and to better understand its users.
3.5.7 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 after we discover such information 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.
3.6 Information provided by others
We collect information that Riders provide about Drivers, and vice-versa, including via ratings and postings on forums or message boards.
Gett may receive information about you if you use any of the other websites it operates or the other services it provides. Gett also works closely with third parties (including, for example, business partners, subcontractors in technical, payment and delivery 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.
3.7 Information about your device
3.7.1 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 the purposes of safety, security, evaluation of the performance of the app or the Site, improvement of the customer experience, fraud prevention and involves the sharing of information about your device including limited personal data, IP address, WiFi and location information with a third-party service provider.
3.7.2 the type, name and use of your device, browser (e.g. the Internet browser you are using such as: Chrome, Internet Explorer, Firefox, and your browser settings) and installed applications and widgets (“Installed Apps”), including the Installed Apps’ name, ID, system, installed date, update date, version, and whether it is on the home page. We also collect your interaction with those Installed Apps, including opening, closing, or uninstalling, and the duration of your use. We do not collect data within the Installed Apps, but rather solely aggregated data concerning use itself;
3.7.3 the visited websites (including the date and duration of such visits);
3.7.4 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
3.7.5 the system status, including device event information such as crashes and system activity.
4. COOKIES AND OTHER WEB FILES OR TAGS
4.2 Most of these cookies used by us will be erased from your hard drive immediately after your browser session (so-called session cookies).
4.3 Other cookies remain saved to your device’s hard drive and enable us to recognize your device in the event of a later visit to our website (so-called persistent cookies). It is particularly these cookies that allow us to make our Site more user-friendly, effective and safe. Thanks to these files, for example, it is possible to display information specifically suited to your personal preferences on a certain webpage. A cookie browser session lasts for the duration of 18 hours.
4.4 The cookies will, among other things, track clicks, and online activity.
4.5.1 to estimate Gett’s audience size and usage pattern and perform other analytics;
4.5.2 to gather information about your approximate geographic location (e.g. city) to provide localised content;
4.5.3 to store information about your preferences and to allow Gett to customise the Site and/or App according to your individual interests and the device or browser you are using;
4.5.4 to continually improve Gett’s Services;
4.5.5 to recognise you when you return to the Site and/or App; and
4.5.6 to prevent fraud and/or abuse.
4.6 The legal grounds for processing the information contained in cookies and other such files or tags consists of the performance or entering into of a contract with you (where cookies are necessary as part of the customer journey), or otherwise our legitimate interests in a safe and user-friendly presentation of our Site.
4.8 The help function in the menu of most browsers explains how to prevent your browser from accepting (some or all) cookies, how you can erase all collected cookies and how to block all future ones.
4.9 Please see the following steps to manage cookies on some common browsers:
In Internet Explorer:
1. Select the item “Internet Options” from the “Extras” menu in the toolbar.
2. Select the “Privacy” tab.
3. Now, you can choose the safety settings for the internet zone. You select the cookies that are to be accepted or denied.
4. Click “OK” to confirm these settings.
1. Select “Settings” from the toolbar.
2. Click “Privacy”.
3. Select “Use custom settings for history” from the dropdown menu.
4. Now you can select whether cookies are to be accepted and for what duration you want to store the cookies. You can also add exceptions and determine the websites that are always or never allowed to store cookies.
5. Click “OK” to confirm these settings.
In Google Chrome:
1. Select the menu icon in the browser toolbar.
2. Select “Settings”.
3. Click the link “Show advanced settings…”.
4. Click “Content Settings…”.
5. In the “Cookies” section, you can select the following settings:
– Erase cookies
– Block cookies by default
– Erase cookies and website data by default after ending your browser session
– Accept exceptions for cookies from certain websites or website domains.
4.10 We remind you however that, in the event of limited cookie settings on your computer, you may no longer be able to use functions of our Site to the fullest extent possible.
Analysis Tools and Internet Technologies
4.13 This website makes use of retargeting technologies that are administered by other operators. Through retargeting, users of our partners’ websites, who were interested in our Site and in our Services before, can be approached with personalized advertisements. Studies show that the inclusion of personalized advertisements that are related to people’s actual interests are more appealing to the user than advertisements without any personal connection. Through retargeting, the incorporation of advertisements is based on the analysis of cookies that display earlier user’s conduct. If you wish to object to this mode of advertisement, you can deactivate cookies and/or delete existent cookies through your browser settings. You can do so by following the instructions under “Cookies”.
4.14 The legal basis for the processing of your data along with the use of collective analytical tools and internet technologies is our legitimate interest in obtaining an analysis of the activities on our website and the user’s and surfer’s behaviour on the Site, notably for research, BI, and product development, as well as our legitimate interest (and the interest of third-parties) in the inclusion of personalized advertisements suited to your interests.
5. CLICKSTREAM DATA
- As you browse the Internet, a trail of electronic information is left at each web site you visit. This information, which is sometimes called “clickstream” data, can be collected and stored by a web site’s server. Clickstream data can tell us the type of computer and browsing software you use, the address of the web site from which you linked to the Site, and in some instances, your email address. We may use clickstream data to determine how much time visitors spend on each page of the Site and how they navigate through the Site. We will only use this information to improve or customise the Site.
6. USES MADE OF THE INFORMATION
6.1 Gett uses information held about you (including both Personal and Anonymous Information) in the following ways:
6.1.1 to register and administer your account;
6.1.2 to provide our various Services, as further detailed on our Site;
6.1.3 to facilitate communications between Riders and Drivers;
6.1.4 to offer customer support;
6.1.5 to ensure 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);
6.1.7 to carry out Gett’s obligations arising from any contracts entered between you and Gett (including but not limited to providing you with the information, goods and/or Services you request from it);
6.1.8 to validate and reimburse valid third-party loyalty coupons for Gett Rides and to notify third-party loyalty partners about qualifying Rides which may accrue third- party loyalty scheme points;
6.1.9 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 13.1);
6.1.10 to provide you with information (by email, sms, messenger, post or telephone) about goods or services offered by Gett’s promotional partners which are relevant to Services you have requested from Gett, or which we otherwise believe 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 13.1);
6.1.11 to allow you to participate in interactive features of Gett’s Services, when you choose to do so;
6.1.12 to contact you for your views on Gett’s Services and to notify you about changes or developments to Gett’s Service;
6.1.13 to administer the Site and the App, and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
6.1.14 as part of Gett’s efforts to keep the Site and the App safe and secure and for the prevention of fraud;
6.1.15 to measure or understand the effectiveness of any advertising Gett serves to you and others, and to deliver relevant advertising to you;
6.1.16 to improve the Site and/or the App including tailoring it to your needs;
6.1.17 to use GPS to identify the location of users;
6.1.18 to comply with Gett’s legal obligations;
6.1.19 to protect Gett’s rights and interests.
6.2 Gett’s third-party service providers may cross-reference your data with data it already holds (independently of Gett) to provide Gett with statistical analysis of the demographic of its users. Gett uses aggregated and anonymous analytics information for internal business planning and other similar purposes.
6.3 Under EU data protection law, all processing of personal data is justified by a “condition” for processing. In the majority of cases any processing will be justified on the basis that:
- you have consented to the processing (e.g. where you provide us with marketing consents or opt-in to optional additional services or functionality);
- the processing is necessary to perform a contract with you (i.e. for Ride Services) or take steps to enter into a contract;
- the processing is necessary for us to comply with a relevant legal obligation (e.g. the disclosure of information to law enforcement or tax authorities); or
- the processing is in our legitimate commercial interests, subject to your interests and fundamental rights (e.g. monitoring which we carry out of your use of the App and the targeting of advertising).
7. SECURITY AND DATA RETENTION
7.1 Gett has implemented administrative, physical and electronic measures designed to protect your information from unauthorized access. 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.
7.3 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.
7.4 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 data. Gett cannot accept any liability for employees or agents acting outside its normal course of business, or for Drivers or any third-parties with whom your Personal Information may be shared (as described in section 1.1) who act outside of the terms of our contracts with them.
7.5 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.
7.6 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 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.
8. DISCLOSURE AND SHARING OF YOUR INFORMATION
8.3 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.
8.4 Riders and Drivers
8.4.1 We share certain information about Riders (including but not limited to name, rating, pickup and drop-off locations, route information, profile picture) with Drivers to enable the scheduling and provision of Rides.
8.4.2 Information provided on any online forum or message board may be viewed by any Riders or Drivers who access the forum or board.
8.5 Service Providers
8.6 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/termsconditions.html 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.
8.7 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, and, depending on the circumstances, we may or may not charge third-parties for such information, or limit the third parties’ use of the same.
8.8 Business Transactions
8.9 Third Party Marketing
As referred to in section 6.1.9, Gett may disclose your information to carefully selected partners which Gett thinks may be of interest to you. These companies may contact you by post, email, telephone or fax for marketing or promotional purposes.
9. LOCATION OF YOUR INFORMATION
9.1 Your Personal Information may be disclosed to Gett Group entities and third-parties in jurisdictions including, but not limited to: Belarus, Cyprus, Israel, Ireland, Russia, The Netherlands, United Kingdom, United States of America.
9.2 Consequently, the data that Gett collects from you may be transferred to, and stored at, 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 your country 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.
10. 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 here. If you do not want your Personal Information to be used, please do not submit your CV.
11. YOUR RIGHTS
11.1 Subject to applicable law, you may have some or all of the following rights in respect of your Personal Information:
11.1.1 Access to own Personal Information: You may have the right to request an overview of your Personal Data in accordance with applicable law. In such a case, where reasonably possible, the overview shall contain information regarding the source (if reasonably available), type, purpose and categories of recipients of the relevant Personal Information. You may also have the right to obtain a copy of the Personal Information held about you. Such right of access can normally be exercised free of charge, however we reserve the right to charge an appropriate administrative fee where permitted by applicable law, for instance where you request multiple copies of your information.
11.1.2 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. 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, deleted or blocked (as appropriate) in accordance with applicable law.
11.1.3 Right to object to or withdraw consent: 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. For instance, 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 on the form on which your data is collected (the registration form). Thereafter, you can follow the opt-out links or unsubscribe directions in emails or SMS messages.
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.
11.1.4 Right to lodge a complaint: You may have the right to lodge a complaint before the relevant data protection authority or supervisory authority.
11.2 To exercise these rights, where applicable, please contact Gett at privacy@Gett.com or use the appropriate functionality in the App or Site. In this context, Gett asks that you provide it with one form of photographic identification so that Gett can verify your identity.
11.3 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: US
California Privacy Rights
Under California’s “Shine the Light” law, Cal. Civil Code § 1798.83, California residents have the right to request in writing from businesses with whom they have an established business relationship: (i) a list of the categories of Personal Information, such as name, address, email address, and the type of services provided to that customer, that a business has disclosed to third parties (including affiliates that are separate legal entities) during the immediately preceding calendar year for the third parties’ direct marketing purposes; and (ii) the names and addresses of all such third parties. To request the above information, California residents can email us at firstname.lastname@example.orgemail@example.com. California residents should include their name, California address, and the nature of their request in their email.
APPENDIX 2: 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.