iCabbi Data Privacy Policy

COOLNAGOUR LIMITED, trading as iCabbi, is a company incorporated under the laws of Ireland with registered number 484271 and having its registered office at Block H, Eastpoint Business Park, Alfie Byrne Road, Dublin 3, D03 XD92, Ireland (“iCabbi”). We process personal data inside and outside of the EU.

Introduction

iCabbi operates a cloud-based automated taxi dispatch system for taxi companies and private hire operators (i.e. our Customers). iCabbi’s software system enables taxi companies to deliver a more holistic service to the passengers who avail of our Customers services (the Passengers) by providing real time updates to Passengers on taxi arrival times, driver availability, journey statistics and facilitating Passenger feedback.

By providing these services to Customers, iCabbi receives personal data relating to the Passengers from its Customers, which may include but is not limited to location, contact details, names and addresses.

This policy describes the data we collect, how it is used and shared, and iCabbi users’ choices regarding how this data is processed. This policy applies to all iCabbi users of our apps, websites, features or other services globally. This policy applies to iCabbi users of iCabbi’s services anywhere in the world, including iCabbi users of ICabbi’s Driver and Passenger Apps, websites, phone systems and other features and services.

This policy applies to:

• Customers (Fleets);
• Passengers: individuals who request or receive transport from an iCabbi Customer; and
• Drivers: individuals who provide transport for an iCabbi Customer.

This policy also applies to those who provide data to iCabbi in connection with an application to use the services provided by iCabbi, or whose data iCabbi otherwise receives in connection with its services. All the users subject to this policy are referred to as “iCabbi users” within this policy.

The practices described in this policy are subject to applicable laws in the territories where we offer iCabbi products and services.

Questions and comments about ICabbi’s data protection practices can be submitted to iCabbi’s Compliance Department (compliance@icabbi.com).

Data Processor

As the provider of, among other elements, a Taxi Dispatch solution, iCabbi processes and stores Personal Data in relation to living individuals, specifically Drivers and Passengers. To that extent, iCabbi acts a Data Processor and has obligations under applicable data protection legislation, which are reflected in this policy.

Due to the nature of the services provided by iCabbi there is a regular and active exchange of Personal Data between iCabbi, its Customers and iCabbi users. In addition, iCabbi exchanges Personal Data with data processors on behalf of its Customers. This is consistent with iCabbi’s obligations under the terms of its contracts with its Customers.

In accordance with EU Data Protection legislation, this data must be processed fairly and lawfully.

iCabbi is committed to ensuring that all staff members have sufficient awareness of the legislation in order to be able to anticipate and identify a data protection issue, should one arise.

iCabbi processes the following categories of data:

• Data created by our Customers, the transport providers, when they use iCabbi’s products.
• Data that Passengers provide to iCabbi when they make a booking with our Customers.
• Data created when Passengers use our services, such as location, usage and device data.
• Data from other sources, such as iCabbi partners and third parties that use iCabbi APIs.

What data does iCabbi need to process a booking?

Data Retention and Deletion

iCabbi retains user profile and other data for as long as iCabbi users maintain their iCabbi account.

iCabbi retains transaction, location, usage and other data for 7 years in connection with regulatory, tax, insurance or other requirements in the places in which it operates. After that period has expired, iCabbi deletes or anonymises the relevant data in accordance with applicable laws. iCabbi retains Voice data for a period of 1 year only and deletes the relevant data once that period has expired in accordance with applicable laws.

iCabbi users may request deletion of their accounts and associated personal data at any time. When a user no longer wants to keep their account active, they are invited to email compliance@icabbi.com. When we receive such requests from a Passenger, we will contact the relevant Customer taxi fleet as they are the Data Controller in respect of that Passenger’s Personal Data. We will then delete the information that we don’t need to retain by law (and, for the information that we are required to retain, we will ensure the appropriate protection mechanisms remain).

Data Sharing and Disclosure

iCabbi does not sell or share users’ Personal Data to third parties for third party direct marketing purposes. We share data with our partners in line with best possible practice (including for legal reasons, in connection with claims or disputes, in response to safety concerns etc.)

iCabbi may also share user data other than as described in this policy if users are notified and consent to the sharing in advance.

In the course of its role as Data Processor, iCabbi engages third-party service providers, or third-party data processors, to process Personal Data on its behalf. In each case, a written contract is in place and / or arrangements documents with the sub-processor, outlining their obligations in relation to the Personal Data, the security measures that they must have in place to protect the data, the specific purpose or purposes for which they are engaged, and the understanding that they will only process the data in compliance with the EU Data Protection legislation.

We use multiple iCabbi service providers and business partners to provide our service. A full list of these can be found at: https://icabbi.com/subprocessor/

These parties may include, for example:

• iCabbi Group entities
• Cloud storage providers
• Payment processors
• Marketing partners
• Data analytics providers
• Security partners
• Professional service providers (e.g. privacy advisors, legal firms)
• Fleet partners
• Vehicle solution vendors or third party vehicle suppliers

We may also share our data with law enforcement bodies, government entities or other third parties as necessary to enforce our Terms of Service, user agreements, or other policies, to protect iCabbi’s rights or property or the rights, safety or property of others, or in the event of a claim or dispute relating to their use of our services.

This also includes sharing user data with others in connection with, or during negotiations of, any merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or into another company.

International

Users resident in the European Union should note that Personal Data may be transferred to certain recipients (mainly other iCabbi entities or our external service providers) who are located outside the European Economic Area (“EEA“) in countries with laws and practices that do not contain equivalent data protection rights for your personal data. Where such transfers are required, we ensure that they only occur where: (i) that country or territory has been deemed by the European Commission to ensure an adequate level of protection for the rights and freedoms of data subjects in relation to the processing of Personal Data; or (ii) an appropriate transfer agreement or other mechanism deemed appropriate by the European Commission has been put in place to protect the personal data.

Updates

We may occasionally update this policy. If iCabbi users use our services after an update, iCabbi users consent to the updated policy.

If we make significant changes to this Privacy Policy, we will notify iCabbi users of the changes through the iCabbi apps or by email. To the extent permitted under applicable law, by using our services after such notice, iCabbi users consent to our updates to this policy.

We encourage iCabbi users to periodically review this policy for the latest data on our privacy practices.