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Privacy Policy

User’s Privacy Policy

Background

Leadryde Technology Ltd trading as LeadRyde, understands that Your privacy is important to You and that You care about how Your personal data is used. We respect and value the privacy of everyone who visits and use LeadRyde User App and website (“Our Website”) and will only collect and use personal data in ways that are described here, and in a way that is consistent with Our obligations and Your rights under the law.

Please read this Privacy Policy carefully and ensure that You understand it. This policy applies to Users of LeadRyde’s services, including Users of LeadRyde App, website or other services.
 

1.0 Definitions and Interpretation

In this Policy, the following terms shall have the following meanings: 

Account: means an account required to access and/or use certain areas and features of LeadRyde User App and Website;

Cookie: means a small text file placed on Your computer or device by Our Website when You visit certain parts of Our Website and/or when You use certain features of Our Website. Details of the Cookies used by Our Website are set out in Part 14, below; and

Cookie Law: means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;
 

2.0   Information About Us

Our Website is owned and operated by Leadryde Technology Ltd, a limited company registered in Scotland under company number SC646433, with its registered office address at 7 Queens Gardens, Aberdeen, AB15 4YD. We have been licensed to carry on the business of a taxi and private hire vehicle booking office according to the requirements of the civil government (Scotland)  Act 1982 (Licensing of Booking Office) Order 2009.

3.0  What Does This Policy Cover?

This Privacy Policy applies only to Your use of LeadRyde User App and Our website. Our Website may contain links to other websites. Please note that we have no control over how Your data is collected, stored, or used by other websites and we advise You to check the privacy policies of any such websites before providing any data to them.

4.0  What Is Personal Data?

Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.

Personal data is, in simpler terms, any information about You that enables You to be identified. Personal data covers obvious information such as Your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
 

5.0  What Are My Rights?

Under the Data Protection Legislation, You have the following rights, which we will always work to uphold:

5.1  The right to be informed about our collection and use of Your personal data. This Privacy Policy should tell You everything You need to know, but You can always contact us to find out more or to ask any questions using the details in Part 17.

5.2  The right to access the personal data we hold about You. Part 13 will tell You how to do this.

5.3  The right to have Your personal data rectified if any of Your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 17 to find out more.

5.4  The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of Your personal data that we Please contact us using the details in Part 17 to find out more.

5.5  The right to restrict (i.e. prevent) the processing of Your personal data.

5.6  The right to object to us using Your personal data for a particular purpose or purposes.

5.7  The right to withdraw consent. This means that, if we are relying on Your consent as the legal basis for using Your personal data, You are free to withdraw that consent at any time.

5.8  The right to data portability. This means that, if You have provided personal data to us directly, we are using it with Your consent or for the performance of a contract, and that data is  processed using automated means.

For more information about our use of Your personal data or exercising Your rights as outlined above, please contact us using the details provided in Part 17.

It is important that Your personal data is kept accurate and up-to-date. If any of the personal data we hold about You changes, please keep us informed as long as we have that data by updating Your personal data using the LeadRyde User App or Your web profile page.

If You have any cause for complaint about our use of Your personal data, You have the right to lodge a complaint with the Information Commissioner’s Office. We would welcome the opportunity to resolve Your concerns ourselves, however, so please contact us in first instance, using the details in Part 17.
 

6.0   What Data Do We Collect and How?

Depending upon Your use of LeadRyde User App and User webpage, we may collect and hold some or all of the personal and non-personal data, using the methods set out in 6.1 – 6.10. Please also see Part 14 for more information about our use of Cookies and similar technologies.

6.1  Identity Information including first name, last name, gender and photo ID: You provide it to us during the account registration process.

6.2  Contact information including email, phone number and address: You provide it to us during the account registration process.

6.3  Credit or debit card details for payment of Your rides: You provide it to us during the account registration process.

6.4  Geographical location information including data such as GPS and IP address: You provide it to us during the account registration process.

6.5  Profile information including Your account ID and password: You provide it to us during the account registration process.

6.6  Records of all communications with You: We collect this during any process of communication, queries, or report with Us.

6.7  Data from third parties including first name, last name, email: You provide this to Us when You request Our Service for Your family and friends.

6.8   Commute/Journey information including the departure and destination postal addresses, records of the booking You made: User provides it when publishing and indexing their journeys on their Account.

6.9   Payment information and History, actual/estimate of fare: We collect this information when You use Our Service.

6.10  Your device location, photos, and media files: We collect this when you are online  and grant Us access to your device for the User App to  function and operate normally to allocate you to  a Driver.

6.10  Cookies related information: We collect this data when You use Our Website or User App.   
 

7.0 How Do You Use My Personal Data?

Under the Data Protection Legislation, We must always have a lawful basis for using personal data. We process and use Your personal data to provide You with LeadRyde Services under the Terms of use of Our website and LeadRyde User App. In order to provide the Service that We are obliged to provide to You, We use Your personal data that You have provided to Us including Your identity and geographical location in order to connect You with a Driver who will administer the taxi service to You. We use Your data in the following ways:

7.1  When You place Booking for taxi Service, we use Your data to allocate a Driver to You and by so doing we make Your identity and location available to Your Driver.

7.2  We Keep record of Your bookings in compliance with Local Authority Booking office licensing regulations. These include date and time of every hire, pickup and drop off location as well as the route taken by the Driver to administer the taxi Service.

7.3  We make all records of the Booking and journeys available for inspection by the Licensing  Authority any time upon reasonable request in compliance with the law.

7.4  We may use Your data to process payment of Your ride fare on behalf of Your Driver using our third-party payment gateway.

7.5  We will use Your data to contact You for reasons only related to providing You with LeadRyde Services which includes but not limited to: in-app notification or e-mail of changes or update to the User App, in-app notification or e-mail on any promotions and reward available to You.

7.6  We will keep Your Data for as long as Your Account is active.

7.7  If Your account is not active, We will keep Your data for as long as the relevant Law requires Us to do so.

7.8  We will make your personal data available to law enforcement agent if it is required for You and Your Driver’s safety and any other reason in order to comply with applicable law upon reasonable request. We will keep records of such request for all cases deemed reasonable by the law enforcement agent which include, fraud, assault, threat to life, misconduct or any conduct that is not considered to comply with the terms and acceptable usage policy of our Services.

7.9  We may initiate a police report where necessary for Your safety or that of Your Driver at our discretion and comply with law enforcement agents if required.

7.10  We will ONLY keep and use Your personal data necessary for our legitimate interests for running Our business to provide Our services to You.

7.11  LeadRyde staff and partners process Your personal data in order to provide Our Services to You under the company’s confidentiality agreement.

With Your permission and/or where permitted by law, we may also use Your personal data for marketing purposes, which may include contacting You by email with information, news, and offers on our products and/or services. You will not be sent any unlawful marketing or spam email. We will always work to fully protect Your rights and comply with our obligations under the Data Protection Legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and You will always have the opportunity to opt-out. We will not share Your data with third parties for marketing purpose and if we plan to do so we will seek Your express permission to that effect.

Third Parties (including Stripe payment provider, Drivers, Google, Twilio, OneSingal) whose content appears on Our Website and App, may use third-party Cookies, as detailed below in Part 14. Please refer to Part 14 for more information on controlling cookies. Please note that we do not control the activities of such third parties, nor the data that they collect and use themselves, and we advise You to check the privacy policies of any such third parties with details shown in part 10.

We will only use Your personal data for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use Your personal data for that purpose. If we do need to use Your personal data in this way, we will let You know.

If we need to use Your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, we will inform You and explain the legal basis which allows us to do so.

In some circumstances, where permitted or required by law, we may process Your personal data without Your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and Your legal rights.

The following explains what we do, the data we use and the lawful basis for which we need them:

7.12    What we do: Registering you on our website and App

           What Data we use: Identity data and contact data

           Lawful Basis: Necessary for our legitimate interest (for running our business, providing our services so drivers can know how to greet you when using their service.

7.13    What we do: Providing and managing your account

           What Data we use: Identity data and contact data

           Lawful Basis: Necessary for our legitimate interest (for running our business, providing our services to you so that we can send account registration confirmation email to you

7.14   What we do: Providing and managing your access to our website

          What Data we use:Identity data and contact data

          Lawful Basis: Necessary for our legitimate interest (for running our business, providing our services to you).

7.15   What we do: Personalising and tailoring your experience on our-                                   –                                   

          What Data we use: Identity data and contact data

          Lawful Basis: Necessary for our legitimate interest (for running our business, providing our services to you).

7.16   What we do: Supplying our products and or services to you

          What Data we use: Identity data, contact data and location data

          Lawful Basis: Necessary for our legitimate interest (for running our business, providing our services to you).

7.17    What we do: Communicating with you

           What Data we use: Identity data, contact data

           Lawful Basis: Necessary for our legitimate interest (for running our business, providing our services to you).

7.18   What we do: Supplying you with information by email that you have opted-in, you may opt out at any time.

          What Data we use:    Identity data, contact data and location data

         Lawful Basis: Necessary for our legitimate interest (essential cookie), consent, (non-essential cookies). Please see our cookie policy for further details.

7.19 What we do:  To manage our relationship with you which includes notifying You of  changes to our terms and privacy                                       

        What Data we use:  Identity data, contact data

        Lawful Basis: Necessary to comply with a legal obligation

 

8.0  How Long Will You Keep My Personal Data?

8.1  We will not keep Your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. We will abide by any legal obligations under applicable law and guidelines issued by relevant data protection authorities to retain Your data for a certain period of time. We will keep all data according the Local Authority licensing conditions as long as You remain an active user of Our Service. The licensing Authority requires Us to keep records of all Boo

8.2  kings and Journey made which include date and time, pick up and drop off location and all relevant data that We have used to process Your Journey.

8.3  These data will be kept for at least three years and if applicable in compliance with other data regulations, may be kept for a longer period. If You uninstall the LeadRyde User App from Your mobile device, it will not result to automatic deletion of Your personal data. If You no longer need or use Our service and User App, please write to Us using the contact details in Part 17 and we will delete Your data accordingly.

8.4  Your personal data will therefore be kept for the following periods or, where there is no fixed period, the following factors will be used to determine how long it is kept. The following section describes your data and how long we keep them for:

8.4.1    Identity and contact data –  We keep this as long as account is active

8.4.2    Location and commute data –  We keep this as long as your account is active.

8.4.3    Account data –  We keep this as long as your account it active

8.4.4    Communication data –  We keep this  as long as your account is active

 

9.0  How and Where Do You Store or Transfer My Personal Data?

Some of our external third parties are based outside the European Union (EU) so their processing of Your personal data will involve a transfer of data outside the EU. The following third parties provide services to Us:

9.1  Your personal data will be stored on our secure server hosted by InMotion hosting in the United States.

9.2  We store your personal data with our payment provider, Stripe UK who process your card payment.

9.3  We share your geo location with Google to process your journey using Google cloud maps and APIs.

9.4  We share your personal data with Twilio who provide SMS message gateway for your OTP.

9.5  We share your personal data with OneSignal who provides the push notification and driver to passenger in-app chat.

9.6  We share your chat communication data with Tawk.to who provides the app-chat platform.

We will store or transfer Your personal data within the European Economic Area (the “EEA”). The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein. This means that Your personal data will be fully protected under the Data Protection Legislation, GDPR, and/or to equivalent standards by law.

We may store or transfer some or all of Your personal data in countries that are not part of the European Economic Area (the “EEA” consists of all EU member states, plus Norway, Iceland, and Liechtenstein). These are known as “third countries” and may not have data protection laws that are as strong as those in the UK and/or the EEA.  This means that we are required by data protection law to ensure that Your personal data is treated just as safely and securely and is protected against unauthorised access and use by applicable legislation as it would be within the UK and under the Data Protection Legislation as follows:

We share Your data with external third parties, as detailed below in Part 10, that are based outside of the EEA. The following safeguards are applied to such transfers:

We will only transfer Your personal data to third countries whose levels of data protection are deemed ‘adequate’.

The security of Your personal data is essential to us, and to protect Your data, we take a number of important measures, including the following:

9.7  limiting access to Your personal data to those employees, agents, contractors, and other third parties with a legitimate need to know and ensuring that they are subject to duties of confidentiality;

9.10  procedures for dealing with data breaches (the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, Your personal data) including notifying You and/or the Information Commissioner’s Office where we are legally required to do so;

9.11  Encrypt Your account password.

 

 10. Do You Share My Personal Data?

10.1  We will not share any of Your personal data with any third parties for any purposes, subject to the following exceptions.

10.2  We will make all Your records (personal data, journeys made) available for inspection at any time to the Licensing Local Authority upon reasonable request. This is a mandatory requirement upon which We must comply.

10.3  In some limited circumstances, we may be legally required to share certain personal data, which might include Yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.

10.4  We may sometimes contract with the following third parties to supply certain products and/or services such as payment gateway (Stripe). Other third parties that provide services to Us are Twilio, Tawk and Google Firebase messaging, chat and push notifications. The payment gateway provider have their Terms of use and we do not control their usage. For payment process, please see the terms on https://stripe.com/gb/legal. For information about the google privacy terms, please consult: https://google.com/policies/privacy/. For information about our server hosting partner, please see  https://www.liquidweb.com/about-us/policies/privacy-policy/
For information about Twilio, please consult: https://twilio.com/legal/privacy

10.5  If any of Your personal data is shared with a third party, as described above, we will take steps to ensure that Your personal data is handled safely, securely, and in accordance with Your rights, Our obligations, and the third party’s obligations under the law, as described above in Part 9.
 

11.0 How Can I Control My Personal Data?

11.1  In addition to Your rights under the Data Protection Legislation, set out in Part 5, when You submit personal data via Our Website and User App, we aim to give You strong controls on Our use of Your data for direct marketing purposes (including the ability to opt-out of receiving emails from us which You may do by unsubscribing using the links provided in Our emails.

11.2  You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent You receiving unsolicited marketing emails. Please note, however, that these services will not prevent You from receiving marketing communications that You have consented to receiving.
 

12.0 Can I Withhold Information?

You may access certain areas of Our Website without providing any personal data at all. However, to use all features and functions available on Our Website, You may be required to submit or allow for the collection of certain data through the registration of Your Account. You may restrict our use of Cookies. For more information, see Part 14.
 

13.0 How Can I Access My Personal Data?

You have full access to all Your personal data that We hold about You via the LeadRyde User App and Your web profile when You log on. You can make any amendment to Your personal data if required. We do not withhold Your access to Your personal data.

If You want to know what personal data we have about You, You can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.

All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 17.

There is not normally any charge for a subject access request. If Your request is ‘manifestly unfounded or excessive’ (for example, if You make repetitive requests) a fee may be charged to cover our administrative costs in responding.

We will respond to Your subject access request within one month of receiving it. Normally, we aim to provide a complete response, including a copy of Your personal data within that time. In some cases, however, particularly if Your request is more complex, more time may be required up to a maximum of three months from the date we receive Your request. You will be kept fully informed of our progress.

 



 

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