Privacy Policy

Last update: April 2021

RECITALS

This Privacy Policy describes the practices relating to personal data that are applied by  Karhoo Europe (UK) Ltd, a limited company, registered in England and Wales under the number 10623359, that has its registered address at c/o WeWork, 5 Merchant Square, London W2 1AY (“ Karhoo”). Karhoo acts as data controller and therefore considers that the protection of the personal data of users of the Taxis powered by Karhoo Platform is an essential priority, and undertakes to inform you on the manner in which it collects, uses and shares your personal data.

The personal data collected are mainly used to enable partners (notably transport service providers) to provide you with the transport services that you selected on the Taxis powered by Karhoo Platform. If you refuse to provide certain items of essential information, you will not be able to use the services offered by the Taxis powered by Karhoo Platform.

Please read this Privacy Policy carefully to ensure that you understand the policy of the Taxis powered by Karhoo Platform regarding your personal data. You are also invited to check this Privacy Policy regularly as it may be subject to updates. The date of the last update provided at the top of this document indicates the last time the Privacy Policy was updated.

Every time you use the Taxis powered by Karhoo Platform in order to make a booking with a Vehicle Fleet gathering drivers, you will be asked to agree specifically to this Privacy Policy after having reviewed the information it contains.

1. HOW IS YOUR DATA USED?

   Karhoo may use the information collected about you for the following specific and limited purposes:

   • To provide services offered by Taxis powered by Karhoo: your personal data are used in order to understand your transport requirements and itinerary, provide you with relevant offers from transport service providers in order to enable you to benefit from a suitable transport service from these transport service providers, duly execute payments and provide you with customer support. Such processing is necessary in order to execute the contract you have entered into with Karhoo.
   • To communicate with you: your personal data are used to monitor and follow your bookings through, and send booking confirmations, reminders of your scheduled journeys or other messages in connection with the services provided by Taxis powered by Karhoo. Such processing is necessary in order to execute the contract you have entered into with Karhoo.
   • Fraud prevention: your personal data may be used for the purposes of fraud prevention. Such processing is necessary in the legitimate interest of Karhoo to prevent fraudulent practices which may affect it or its clients, in particular identity or bank detail theft.
   • To improve the Taxis powered by Karhoo Platform: your personal data may be used to analyse the manner in which you use the Taxis powered by Karhoo Platform, in order to improve statistical analysis, determine the most popular travel times and routes and to improve itineraries. For this purpose, Karhoo ensures that the data relating to your use of the Taxis powered by Karhoo Platform are anonymised. This processing is necessary in our legitimate interest to constantly improve the conditions in which we provide our services and to ensure that we provide a high quality of service with optimal functionalities.
2. INFORMATION ABOUT YOU THAT WE MAY COLLECT

   What personal data are collected?

   Karhoo collects only personal data that are strictly necessary for its purposes defined above, in particular, the supply of services of the Taxis powered by Karhoo Platform, which are as follows:

   • Name and forename
   • E-mail
   • Telephone number
   • Loyalty card number
   • Bank details (the following information only: type of card used, country of issue of the card, name of the bank, identification number of the bank)
   • Details of the trip (including details of the associated railway trip, details of the journey by private car with VTC driver / taxi including pick-up location and destination, amount charged for the trip, name of the transport provider and type of vehicle)
   • Number of visits to the Taxis powered by Karhoo Platform
   • Technical information: the device you use, your IP address, your approximate location deducted from your IP address, the mobile network used, the operating system and version number that you use, the browser and version number that you use, the time zone, certain single advertising identifiers connected to your device (such as the Apple "IDFA" advertising identifier, the Google "Android Advertising ID" or statistical identifiers).

   How is your personal data collected?

   Karhoo collects your data when you fill out a booking form.

   For how long is your data stored?

   Your personal data are stored only for periods that are strictly necessary:

   • to provide services offered on the Taxis powered by Karhoo Platform;
   • for compliance with statutory and regulatory constraints, in particular with dispute settlements; and
   • to communicate personalised offers of services.

   In particular:

   • Karhoo stores data relating to identification and the booking, for a period of 7 years from the date of execution of the transport.
   • Karhoo stores data relating to identification of the client for a period of 7 years from the date of the booking.
   • Cookies are stored for a maximum period of 13 months from when they are placed on your computer or mobile device.

   What security measures are implemented to protect your personal data?

   Karhoo is particularly concerned with the security of your data and dedicate significant human and technical resources to protect them from loss, unauthorised access, their use, modification or deletion.

   A strict security policy is in force to define the procedures, working methods and technical protection rules to be implemented. The following is a non-exhaustive list of practical examples of security measures that are in force:

   • automated protection systems against cyberattacks are activated;
   • IT product codes on the Karhoo website are subject to security code reviews;
   • automated tools periodically conduct security tests on websites;
   • the security of the websites are audited by firms with expertise in this matter:
   • access to clients' personal data is subject to strict access control; and
   • experts in cybersecurity may intervene at any time to deal with security breaches.

   Cookies and other similar technologies

   Karhoo uses cookies and other similar technologies to distinguish you from other users of the Karhoo Taxis Platform. This helps them to provide you with the best possible experience when you use the Taxis powered by Karhoo Platform and enables them to improve the service. A cookie is a small file of letters and numbers that is stored on your browser on the hard drive of your computer or your smartphone.

   For example, cookies may be used to collect information on your use of the Taxis powered by Karhoo Platform during your current session and beyond (including the pages you view and the files you download), on your operating system, your browser, your internet access supplier, your domain name and IP address, the website that you consulted before ours or the link that you used to leave our website. If you are concerned about having cookies on your computer, you may configure your browser to refuse all cookies or to be notified when a cookie is placed, thereby allowing you to accept or refuse it. You may also delete cookies from your computer. If, however, you decide to block or delete cookies, certain functions of the Taxis powered by Karhoo Platform will not be able to operate properly. Karhoo may also collect and store information on your computer or mobile device by using data in cache and your browsing history (including HTML 5) or alternative mechanisms and other technologies.

3. HOW CAN YOUR PERSONAL DATA BE SHARED WITH THIRD PARTIES?

   Karhoo may transfer your personal data to third parties. Where Karhoo transfers personal data it is done for the following reasons:

   • To provide the services offered on the Taxis powered by Karhoo Platform: personal data is transferred to the transport service providers in order to enable you to benefit from a suitable transport service.
   • Karhoo uses technical subcontractors to operate the Taxis powered by Karhoo Platform, especially for:
     • hosting the Taxis powered by Karhoo Platform;
     • the technical and IT infrastructure of the Taxis powered by Karhoo Platform;
     • customer support of the Taxis powered by Karhoo Platform;
     • detecting fraud mechanisms on the Taxis powered by Karhoo Platform; and
     • the payment service on the Taxis powered by Karhoo Platform.
   • For legal reasons and for the prevention of fraud: your personal data may be transferred to the public authorities where Karhoo is legally required or authorised to:
     • comply with applicable law;
     • conduct anti-fraud control, investigate, prevent or take measures against illegal activities, suspected fraud, breaches of our general terms, or situations involving threats to our proprietary rights or the property or physical integrity/safety of any person or third party, or to cooperate in the maintenance of public order/compliance with the law;
     • establish, protect or exercise their rights or defend them selves against legal proceedings.

   Karhoo applies appropriate operational and contractual measures to ensure that all processing firms, within the meaning of the rules applicable to personal data, who have access to your personal data, are in compliance with applicable regulations.

   The personal data collected by Karhoo may be stored or transferred to a location outside the European Economic Area ("EEA"). Where Karhoo transfers your data outside the EEA, (i) it does so towards countries that provide an adequate level of protection (according to the European Commission) or (ii) it implements appropriate measures of protection for these transfers, in the form of standard contract clauses / data protection provisions adopted by the European Commission.

   If you wish to obtain further information on these warranties and the procedures for obtaining a copy thereof, please contact:

   Karhoo at the following address: c/o WeWork, 5 Merchant Square, London W2 1AY.

4. WHAT ARE YOUR RIGHTS?

   In accordance with the rules relating to personal data protection, you have the following rights concerning your personal data, which you are entitled to exercise against the Taxis powered by Karhoo Platform:

   • Right of access: you have the right to know what personal data concerning you is held by Karhoo;
   • Right of rectification and deletion: you have the right to rectify the personal data concerning you and/or to request their deletion;
   • Right to restriction and objection to processing: you have the right to object to the manner in which your personal data is used and/or to restrict the manner in which they are used;
   • Right to portability: you may ask Karhoo to send you data concerning you in a structured, commonly used and machine-readable format.

   You may also withdraw your consent to the processing of your personal data at any time. The withdrawal of your consent may prevent you from gaining access to the Taxis powered by Karhoo Platform.

   To exercise the aforementioned rights, please contact Karhoo at the following email address: DPO@Karhoo.com.

   We inform you that for security reasons, you will be asked to provide identity information in order to exercise those rights. Additionally, the enforcement of these rights is not an absolute right and may be restricted on the grounds of legitimate interest or for legal reasons.

   In the event of disagreement on the use of your data, you may send your requests to the Data Protection Officer of Karhoo: DPO@Karhoo.com.

   You may also file a complaint with the competent supervisory authority:

   Information Commissioner’s Office
   Wycliffe House
   Water Lane
   Wilmslow
   Cheshire
   SK9 5AF.

   or visit www.ico.org.uk