Privacy Policy

Background

Navhoo understands that your privacy is important to you and that you care about how your information is used and shared online. We respect and value the privacy of everyone who visits Our Site and will only collect and use information in ways that are useful to you and in a manner consistent with your rights and Our obligations under the law.

This Policy applies to Our use of any and all data collected by us in relation to your use of Our Site. Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance of Our Privacy Policy is deemed to occur upon your first use of Our Site. If you do not accept and agree with this Privacy Policy, you must stop using Our Site immediately.

1. 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 Our Site;
“Cookie”	means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in section 12, below;]
“Our Site”	means this website, www.navhoo.com
“UK and EU Cookie Law”	means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended in 2004, 2011 and 2015; and
“We/Us/Our”	Means Navhoo Tech Limited, a limited company registered in England under 09781483, whose registered address is 694 Romford Road, London. E12 5AJ.

2. Data Protection Officer

• Our data protection officer can be contacted at dev@navhoo.com.

3. Scope – What Does This Policy Cover?

This Privacy Policy applies only to your use of Our Site. It does not extend to any websites that are linked to from Our Site (whether We provide those links or whether they are shared by other users). 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. What Data Do We Collect?

Some data will be collected automatically by Our, other data will only be collected if you voluntarily submit it and consent to Us using it for the purposes set out in section 5, for example, when signing up for an Account. Depending upon your use of Our Site, We may collect some or all of the following data:

1. Information you give us:

• This is information about you that you give us directly when you interact with us. EU privacy law requires us to explain to users, for each category of information we collect, why we collect it and the “lawful basis” on which we process the data – legalese for the reason recognised by EU privacy law which allows us to collect and use your information as set out in this Privacy Policy.

• Personal Data type collected

  • First Name
  • Middle Name;
  • Last Name;
  • Email;
  • Profile image/ Photo (optional for Users);
  • Date of birth (for Driver Partners only);
  • Gender (for Driver Partners only);
  • Geographic address.
  • Mobile number (including country).
  • Payment information:
    • for Users, this includes billing information, credit card details and your student/senior status (where appropriate);
    • for Driver Partners, this may include bank account details.
    • For Users, feedback you provide on Driver Partners.

• Lawful basis for processing

• Purpose of processing

  • Set-up and manage account;
  • Provision of Services;
  • Customer service;
  • Internal operations (including troubleshooting, data analysis, testing, research, statistical and survey purposes);
  • For analysis and report generation purposes (including developing new features, support service improvements on payments, pricing, routing, algorithmic dispatching efficiencies, for quality of Service review and fraud detection);
  • Improve service functionality and efficiency;
  • Prevention of fraud/ integrity of systems and manage accounts;
  • In relation to Driver Partners, for background checks to assess suitability of Driver Partners and protect Users;
  • In relation to Driver Partners, to investigate ratings, User feedback and complaints;
  • Promote the Services to you, with your consent.
  • Set-up and manage account;
  • Provision of Services and required communications in relation to the provision of Services;
  • Communicate with you in relation to a Ride;
  • If you are a Driver Partner, promote the Services to you, with your consent.

• Users

  • Our legitimate interests in authenticating authorised Users so we can provide the Service, and enable Users to connect with Driver Partners and, with the User’s consent, promote the use of the Services to them, and as is necessary for the purpose of the contract in order to provide the Service.

• Driver Partners:

  • Our legitimate interests and as is necessary for the purpose of the contract between Navhoo and the Driver Partner.

• Necessary for the purpose of the contract between us, and, if you are a Driver Partner, to promote the Services to you, with your consent.

• Necessary for the purpose of the contract between us and, where you are a Driver Partner only, for our legitimate interests.

• In relation to Users, we use this data in relation to

  • Provision of Services (including billing and payment on behalf of Driver Partners);
  • Customer service

• In relation to Driver Partners, we use this data to

  • Set-up and manage account;
  • Pay you what you are entitled to in respect of the transportation
  • services provided to Users;
  • Internal operations (including troubleshooting, data analysis, testing, research, statistical and survey purposes);
  • Prevention of fraud/ integrity of systems and manage accounts.
  • Driver Partner assessment and follow-up;
  • Investigation of poor ratings and complaints.
  • Understanding how Driver Partners learn about us so we can better plan the provision of our Services;
  • Providing referral incentives where applicable.
  • Set-up and manage account;
  • Ensure the Services are compliant with regulatory requirements;
  • Provision of Services;
  • Internal operations (including troubleshooting, data analysis, testing, research, statistical and survey purposes);
  • Prevention of fraud/ integrity of systems and manage accounts;
  • Ensuring the suitability of Driver Partners and the safety of Users.
  • To protect the trust and safety of the Users, and the general public;
  • For insurance purposes;
  • To ensure compliance with Navhoo policies and standards

• Our legitimate interests in monitoring quality of Services and User experience.

• For Driver Partners

  • How did you hear about Navhoo (drop-down);
  • Referral name (optional).

• Our legitimate interests in understanding how Driver Partners learn about us so we can better plan the provision of our Services.

• For Driver Partners

  • Vehicle information and condition – picture of car (inside and out) and presence of in car equipment;
  • Insurance information;
  • Any licence or permission Driver Partner has or needs under local regulations;
  • Driver’s license;
  • Vehicle registration;
  • Road or other tax details for Driver Partner or vehicle (where required);
  • Traffic violations (including accidents) occurred on the mobile application;
  • Ticket, fines and violations;
  • Background check.

• Our legitimate interests and as is necessary for the purpose of the contract between us.

• For Driver Partners

  • Physical/ mental health – only drug/alcohol test in the event of a complaint/safety concern.  

• Your consent.

• Providing the above information is a requirement of our agreement with you because we can’t provide the Services without it.

• Information we collect about you from your use of our Services:

• We will automatically collect information from you each time you use our Services.

• Personal Data type collected

• Lawful basis for processing

• Purpose of processing

  • Provision of Services;
  • Customer service;
  • Internal operations (including troubleshooting, data analysis, testing, research, statistical and survey purposes);
  • Improve service functionality and efficiency;
  • Prevention of fraud/ integrity of systems and manage accounts;
  • To optimise and personalise your experience of the Services;
  • For analysis and report generation purposes (including developing new features, support service improvements on payments, pricing, routing, algorithmic dispatching efficiencies, for quality of Service review and fraud detection).
  • Provision of Services;
  • Internal operations (including troubleshooting, data analysis, testing, research, statistical and survey purposes);
  • For analysis and report generation purposes (including developing new features, support service improvements on payments, pricing, routing, algorithmic dispatching efficiencies, for quality of Service review and fraud detection);
  • Improve service functionality and efficiency;
  • Prevention of fraud/ integrity of systems and manage accounts.
  • To optimize and personalize the user experience on the App;
  • In relation to Users, customer service.
  • Provision of Services;
  • Internal operations (including troubleshooting, data analysis, testing, research, statistical and survey purposes).
  • Improve service functionality and efficiency;
  • Prevention of fraud/ integrity of systems and manage accounts;
  • To optimise and personalise the user experience on the App;
  • In relation to Users, Customer service.

• 4.1.24 In relation to Users only:

  • Technical details:
    • App version;
    • User ID (unique ID our platform assigns to each User);
    • Build;
    • Operating system;
    • Phone make/ model.
  • Dates and times of Rides requested and fulfilled;
  • Cost of Ride;
  • Remaining credit
  • Driving history (usage of Navhoo’s Service) – driving times; ratings; feedback from Rides; escalation/ incident history);
  • Routes used (in relation to Driver Partners, this includes data on the differences between actual route taken and route instructed by Navhoo’s system);
  • Trip records.
  • Preferred language/ language settings on device.
  • Communications – SMSs and emails between Navhoo/Driver Partner/Users.
  • For analysis and report generation purposes (including developing new features, support service improvements on payments, pricing, routing, algorithmic dispatching efficiencies, for quality of Service review and fraud detection);
  • Improve service functionality and efficiency;
  • Prevention of fraud/ integrity of systems and manage accounts.
  • To optimize and personalize the user experience on the App;
  • In relation to Users, customer service.
  • Provision of Services;
  • Internal operations (including troubleshooting, data analysis, testing, research, statistical and survey purposes).
  • Improve service functionality and efficiency;
  • Prevention of fraud/ integrity of systems and manage accounts;
  • To optimise and personalise the user experience on the App;
  • In relation to Users, Customer service.

• Necessary for the purposes of our contract so we can arrange for Rides and payment and in our legitimate interests in understanding and improving our technology and Services

• Our legitimate interests.

• Our legitimate interests.

• Necessary for the purpose of the contract between us.

5. How Do We Use Your Data?

• All personal data is stored securely in accordance with the EU General Data Protection Regulation (Regulation (EU) 2016/679) (GDPR). For more details on security see section 6,below.
• We use your data to provide the best possible services to you. This includes:
  • Providing and managing your access to Our Site;
  • Personalising and tailoring your experience on Our Site;
  • Supplying Our services to you;
  • Personalising and tailoring Our services for you;
  • Responding to communications from you;
• In some cases, the collection of data may be a statutory or contractual requirement, and We will be limited in the services We can provide you without your consent for Us to be able to use such data.
• With your permission and/or where permitted by law, We may also use your data for marketing purposes which may include contacting you by support@navhoo.com with information, news and offers on Our services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, as amended in 2004, 2011 and 2015.
• Under GDPR we will ensure that your personal data is processed lawfully, fairly, and transparently, without adversely affecting your rights. We will only process your personal data if at least one of the following basis applies:
  • a) you have given consent to the processing of your personal data for one or more specific purposes;
  • b) processing is necessary for the performance of a contract to which you are a party or in order to take steps at the request of you prior to entering into a contract;
  • c) processing is necessary for compliance with a legal obligation to which we are subject;
  • d) processing is necessary to protect the vital interests of you or of another natural person;
  • e) processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller; and/or
  • f) processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by the fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.

6. How and Where Do We Store Your Data?

• We only keep your data for as long as We need to in order to use it as described above in section 5, and/or for as long as We have your permission to keep it. In any event, We will conduct an annual review to ascertain whether we need to keep your data. Your data will be deleted if we no longer need it in accordance with the terms of our Data Retention Policy. Our Data Retention Policies are:
• Your data will only be stored within the European Economic Area (“the EEA”) (The EEA consists of all EU User states, plus Norway, Iceland and Liechtenstein).
• Data security is of great importance to Us, and to protect your data We have put in place suitable physical, electronic and managerial procedures to safeguard and secure data collected through Our Site.
• Notwithstanding the security measures that We take, it is important to reUser that the transmission of data via the internet may not be completely secure and that you are advised to take suitable precautions when transmitting to Us data via the internet.

7. Do We Share Your Data?

• We do not share your data with any third Party.
• In certain circumstances We may be legally required to share certain data held by Us, which may include your personal information, for example, where We are involved in legal proceedings, where We are complying with the requirements of legislation, a court order, or a governmental authority. We do not require any further consent from you in order to share your data in such circumstances and will comply as required with any legally binding request that is made of Us.

8. What Happens If Our Business Changes Hands?

• We may, from time to time, expand or reduce Our business and this may involve the sale and/or the transfer of control of all or part of Our business. Data provided by users will, where it is relevant to any part of Our business so transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Privacy Policy, be permitted to use the data for the purposes for which it was originally collected byUs.
• In the event that any of your data is to be transferred in such a manner, you will not be contacted in advance and informed of the changes.

9. How Can You Control Your Data?

• When you submit information via Our Site, you may be given options to restrict Our use of your data. We aim to give you strong controls on Our use of your data (including the ability to opt-out of receiving emails from Us which you may do by unsubscribing using the links provided in Our emails).

10. Your Right to Withhold Information and Your Right to Withdraw Information After You Have Given it

• You may access certain areas of Our Site without providing any data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certaindata.
• You may restrict your internet browser’s use of Cookies. For more information, see section 12.
• You may withdraw your consent for Us to use your personal data as set out in section in 5 at any time by contacting Us using the details set out in section 15, and We will delete Your data from Our systems.However, you acknowledge this may limit Our ability to provide the best possible services to you.

11. How Can You Access Your Data?

• You have the legal right to ask for a copy of any of your personal data held by Us(where such data is held).Please contact Us for more details at support@navhoo.com, or using the contact details below in section 14.

12. What Cookies Do We Use and What For?

• Our Site may place and access certain first party Cookies on your computer or device. First party Cookies are those placed directly by Us and are used only by Us. We use Cookies to facilitate and improve your experience of Our Site and to provide and improve Our services. For more details, please refer to section 5, above, and to section 12.6 below. Wehave carefully chosen these Cookies and have taken steps to ensure that your privacy is protected and respected at all times.
• By using Our Site you may also receive certain third party Cookies on your computer or device. Third party Cookies are those placed by websites, services, and/or parties other than Us.
• All Cookies used by and onOur Site are used in accordance with current English and EU Cookie Law.
• Before Cookies are placed on your computer or device,you will be shown a pop-up, message bar requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling Us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of Our Site may not function fully or as intended. You will be given the opportunity to allow only first party Cookies and block third party Cookies.
• Our Site uses analytics services provided by Google Analytics. Website analytics refers to a set of tools used to collect and analyse usage statistics, enabling Us to better understand how people use Our Site. This, in turn, enables Us to improve Our Site and the services offered through it. You do not have to allow Us to use these Cookies, as detailed below, however whilst Our use of them does not pose any risk to your privacy or your safe use of Our Site, it does enable Us to continually improve Our Site, making it a better and more useful experience for you.
• The analytics service(s) used by Our Site use(s) Cookies to gather the required information.
• You can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all cookies or only third party cookies. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.
• You can choose to delete Cookies at any time however you may lose any information that enables you to access Our Site more quickly and efficiently including, but not limited to, login and personalisation settings.
• It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.

The tables below list some of the internal and third-party cookies we use. As the names, numbers, and purposes of these cookies may change over time, this page may be updated to reflect those changes. For more information on how we use these cookies, please refer to our Cookies Policy.

Third-Party Cookies:

13. Summary of Your Rights under GDPR

• Under the GDPR, you have:
• the right to request access to, deletion of or correction of, your personal data held by Us;
• the right to complain to a supervisory authority;
• be informed of what data processing is taking place;
• the right to restrict processing;
• the right to data portability;
• object to processing of your personal data;
• rights with respect to automated decision-making and profiling (see section 14 below).
• To enforce any of the foregoing rights or if you have any other questions about Our Site or this Privacy Policy, please contact Us using the details set out in section 15 below.

14. Automated Decision-Making and Profiling

• In the event that We use personal data for the purposes of automated decision-making and those decisions have a legal (or similarly significant effect) on You, You have the right to challenge to such decisions under GDPR, requesting human intervention, expressing their own point of view, and obtaining an explanation of the decision from Us.
• The right described in section 14.1 does not apply in the following circumstances:
  • a) The decision is necessary for the entry into, or performance of, a contract between the You and Us;
  • b) The decision is authorised by law; or
  • c) You have given you explicit consent.
• Where We use your personal data for profiling purposes, the following shall apply:
  • a) Clear information explaining the profiling will be provided, including its significance and the likely consequences;
  • b) Appropriate mathematical or statistical procedures will be used;
  • c) Technical and organisational measures necessary to minimise the risk of errors and to enable such errors to be easily corrected shall be implemented; and
  • d) All personal data processed for profiling purposes shall be secured in order to prevent discriminatory effects arising out of profiling.

15. Contacting Us

If you have any questions about Our Site or this Privacy Policy, please contact Us by email at support@navhoo.com, or by post at 694 Romford Road,London. E12 5AJ. Please ensure that your query is clear, particularly if it is a request for information about the data We hold about you.

16. Changes to Our Privacy Policy

We may change this Privacy Policy as we may deem necessary from time to time, or as may be required by law. Any changes will be immediately posted on Our Site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of Our Site following the alterations. We recommend that you check this page regularly to keep up-to-date.