Privacy Policy

Effective Date: 08 September, 2017

Karhoo Europe (UK) Limited, its subsidiaries, parent and sister companies and other companies that are part of our group such as joint venture partnerships (collectively, “we”, “us”, “our” or “Karhoo”) respects users’ privacy and is committed to informing you about how we collect, use, and share information about you. This Privacy Policy describes our practices with respect to the information we collect from or about our users in connection with the Karhoo mobile applications, websites and other services (together, the “Karhoo Platform”). This Privacy Policy applies to personal information processed about persons anywhere in the world who use our Karhoo Platform.  This Privacy Policy does not apply to information we collect from or about drivers, participating transportation providers or any other persons who use the Karhoo Platform to provide transportation services.

Please read this Privacy Policy carefully to understand our views and practices regarding your information and how we will treat it. In addition, we recommend that you review our Privacy Policy periodically, because we may revise it at any time. The “Effective Date” at the top of this page indicates when our Privacy Policy was last revised.  Each time you use the Karhoo Platform or provide us with information, you acknowledge the practices described in this Privacy Policy at that time.

The controller of personal data for data protection purposes is Karhoo Europe (UK) Limited, with its registered office address at 2 Eastbourne Terrace, London, United Kingdom, W2 6LG.

INFORMATION WE MAY COLLECT ABOUT YOU

Karhoo collects information about its users through their use of and in connection with the Karhoo Platform.  For the purposes of this Privacy Policy, “Personal Information” is information relating to an identified or identifiable person that Karhoo collects about our users, as further described below.

• Personal Information You Give Us. You may give us your Personal Information directly, for example, when you fill in forms on the Karhoo Platform, correspond with us (for example, without limitation, by email or chat), register to use the Karhoo Platform, access our mobile applications or create an account, use the Karhoo Platform to book transportation services or rate the services, share data via the Karhoo Platform’s social media functions, enter a competition, promotion, or survey or report a problem with the Karhoo Platform. The Personal Information you give us directly or collected through your use of the Karhoo Platform may include your:

o Name

o Address

o Email address

o Phone number

o Username and password

o Payment information

o Date of birth

• Personal Information We Collect from Your Device. Each time you log onto your account or use the Karhoo Platform, we may, in some cases automatically, collect the following information:

o Device Information. We may collect information from or through the device you use to connect to the Karhoo Platform, including, for example, the type of device, the IP address, the approximate location derived from an IP address, the mobile network, the operating system and version, the browser and version or the time zone setting or unique device identifiers (such as IDFA, Android Advertising or statistical IDs).

o Log Information. We automatically receive and record certain details about your use of the Karhoo Platform, including but not limited to, web traffic data, web logs and communication data, trip details such as trip duration, distance, and trip amount and other information about your activity on the Karhoo Platform.

o Cookies and Other Similar Technologies. We use cookies and other similar technologies to distinguish you from other users of the Karhoo Platform. This helps us to provide you with the best possible experience when you use the Karhoo Platform and allows us to improve the Karhoo Platform. A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer or mobile device. For example, cookies can be used to collect information about your use of the Karhoo Platform during your current session and over time (including the webpages you view and the files you download), your operating system and browser type, your internet service provider, your domain name and IP address, the website that you visited before our website, and the link that you use to leave our website. If you are concerned about having cookies on your computer, you can set your browser to refuse all cookies or to indicate when a cookie is being set, allowing you to decide whether to accept it. You can also delete cookies from your computer. However, if you choose to block or delete cookies, certain features of the Karhoo Platform may not operate correctly.We also may collect and store information on your computer or mobile device using application data caches and browser web storage (including HTML 5) or alternative mechanisms and other technology.

o Web Beacons.  The Karhoo Platform or the emails that you receive from Karhoo may use an application known as a “web beacon” (also known as a “clear gif” or “pixel tag”). A web beacon is an electronic file that usually consists of a single-pixel image and can be embedded in a web page or in an email to transmit information, which could include Personal Information. For example, it allows an email sender to determine whether a user has opened a particular email.

o Precise Location. If you permit the Karhoo Platform to access location services, we may collect precise location from your device through GPS, WiFi, cell phone signals, iBeacons (which use Bluetooth) or other technologies.  We also collect location information that you share with us during your use of the Karhoo Platform, such as pick-up, drop-off or bookmarked street addresses.  We need to process certain location information to provide the Karhoo Platform and services to you.

• Personal Information We Collect from Other Sources.

o We work closely with third parties (including, for example, participating transportation providers, fraud checking companies, providers in technical, payment and delivery services, advertising networks, analytics providers and search information providers), and we may receive, collect, store, and use information about you from them.

o If you also choose to connect your social network accounts and login credentials to your Karhoo account, such as through Facebook and Twitter, we may receive information about you or your social network connections and contacts and you are permitting us to use and store that information related to the account.

• We may partner with certain third parties to collect the Other Information and to engage in analysis, auditing, research and reporting or for use in providing online interest-based advertising on our behalf.  These third parties may use web logs or web beacons, and they may set and access cookies or similar technologies on your device.  They may also use information about your use of the Karhoo Platform to help target non-Karhoo advertisements based on your online activity in general.  To learn more about such targeted advertising and how you can either accept or reject (by opt-out) such advertising, visit, http://www.aboutads.info/choices/, http://www.youronlinechoices.eu/ or http://www.networkadvertising.org/understanding-online-advertising. The Karhoo Platform uses Google Analytics to help collect and analyse certain information about you (such as age, gender and interests).  To learn more about Google Analytics and how to opt-out, follow this link: https://support.google.com/analytics/answer/2799357. • Personal Information We May Collect about You. We may combine Personal Information collected through the Karhoo Platform with other information that we or third parties collect about you in other contexts—such as our communications with you via email, phone or otherwise or your customer service records.  We will treat all such information as Personal Information and protect it in accordance with this Privacy Policy.

HOW WE USE INFORMATION ABOUT YOU

Karhoo may use the information that We collect from you:

• To Provide Our Services to You and Improve the Karhoo Platform. We use information to provide our services to you through the Karhoo Platform, to carry out fraud checks, to process and complete payments or transactions, to forward trip information to and from participating transportation providers and to provide customer support to our users. We also may use Personal Information to improve the Karhoo Platform, such as to improve travel recommendations and estimates, determine popular travel times and locations and improve routes.

It is necessary for us to use Personal Information in this way in order to fulfil our contract with you and we have a legitimate interest to process your Personal Information in order to provide and improve the Karhoo Platform, our products and services, carry out fraud checks, administer accounts and run our business.

• To Contact You. Subject to applicable law, we or our third-party service and business providers may communicate with you via email, phone or otherwise about the Karhoo Platform and services. Such communications are designed to make your Karhoo experience more efficient and may include, but are not limited to: notifications about the Karhoo Platform and services (including important news that could affect your relationship with us), reminders about your scheduled rides, alerts about potential available rides and other service communications.It is It necessary for us to use Personal Information in this way in order to fulfil our contract with you.

• For Marketing and Advertising Purposes. Subject to applicable law and as described in this Privacy Policy, we may use your Personal Information to deliver marketing communications and promotions to you and provide you with information about products and services that may interest you, including promotions and new or existing features and other matters we deem necessary from time to time.  These types of communications may also contain advertising, such as banner ads and special offers.

We have a legitimate interest to process Personal Information for direct marketing and advertising purposes and we rely on consent as a basis for direct marketing where we are legally required to do so.

• To Connect You with Products, Services or Promotions from Our Business Partners. Where you consent, we may use and disclose Personal Information to our third-party business partners when you purchase, register, or make reservations for products or services offered or sponsored by such third parties on the Karhoo Platform. We also may use or share your Personal Information when you elect to receive communications (such as emails, text messages or mail) from third parties or participate in contests, sweepstakes, or other programs (such as discount or rewards programs) offered or sponsored by third parties on the Karhoo Platform.

• To Provide Social Networking and Other Sharing Features. Where you consent by enabling social networking or other sharing features, we may use Personal Information to enable social networking features, to allow you to comment on the Karhoo Platform, to report an issue about a trip, to find and connect with your friends (when instructed by you) and in connection with other sharing features.

• For Legal Purposes. We may use and share Personal Information for legal purposes, including as described below in the section titled “How We Share Information with Third Parties”.

This processing is necessary for compliance with legal obligations to which we or the relevant regulator/law enforcement agency are subject.

• To Manage Our Business. We may use Personal Information to help us efficiently operate the Karhoo Platform, to count and recognize visitors to the Karhoo Platform, to enable certain features on the Karhoo Platform and for other purposes related to managing our business.

We have a legitimate interest to process Personal Information as necessary and proportionate to manage and run our business.

• For Analytics and to Improve the Karhoo Platform. We may use Personal Information to analyse how visitors use the Karhoo Platform and its features, to improve the Karhoo Platform and enhance users’ experiences, to create new products and services or improve our existing products and services and to enable additional analytics and research concerning the Karhoo Platform.  Karhoo may link or combine the Personal Information it collects to understand patterns, trends, opportunities and improvements.

We have a legitimate interest to process Personal Information in this way to improve and enhance the Karhoo Platform, our products and services.

• To improve transportation providers, municipalities and other partners’ services.

HOW WE SHARE INFORMATION WITH THIRD PARTIES

Subject to applicable law, we may share your Personal Information:

• With Marketing Partners and Other Third-Party Service Providers. To operate the Karhoo Platform, including processing your transactions and supporting your activities on the Karhoo Platform, we may share your Personal Information with our agents, participating transportation providers, representatives, contractors and other service providers. These service providers may provide us with support services such as origination of communications, receipt or support services, customer relationship management services and order fulfillment.

• With our group companies. We may share information between our group companies to provide the Karhoo Platform and our products and services and for our business and administrative purposes. Where we share your Personal Information with our group companies, each group company will comply with the terms of this Privacy Policy with respect to its use and disclosure of such Personal Information.

• With Business Partners. As described above, we may provide Personal Information to our third-party business partners when you purchase, register or make reservations for products, services, sweepstakes or other programs offered or sponsored by third parties on the Karhoo Platform or when you elect to receive communications from them.

• With Third-Parties through Their Websites and Services. The Karhoo Platform may enable you to share information directly on or through websites or online services operated by third parties. For example, the Karhoo Platform may contain links to third-party websites that incorporate comment, chat room, forum or other social media features.  The Karhoo Platform also contains a Facebook “like” button and a Twitter “follow” button. If you choose to use these features, you may disclose your information not just to those third-party websites and services, but also to their users and the public more generally.  You are in control of how you use these features and use of your Personal Information by those third parties is subject to their privacy policies available on their websites.

• For Legal and Fraud Checking Purposes. We may disclose your Personal Information when we believe that doing so is necessary or permitted to:

o comply with applicable law;

o carry out fraud checks, investigate, prevent, or take action regarding illegal activities, suspected fraud, violations of our terms and conditions, or situations involving threats to our property or the property or physical safety of any person or third party or to cooperate with law enforcement;

o establish, protect, or exercise our legal rights or defend against legal claims; or

o facilitate a transfer, sale, financing, securitization, insuring, assignment, bankruptcy or other disposal of all or part of our business or assets.

Note that we may use third party fraud detection companies to help us to identify fraud.  Personal Information relating to you may be transferred to Ravelin (a fraud detection company) and a separate data controller, who will use it to detect whether you have ever: committed fraud; been an accessory to such a crime; or attempted any of the same and Ravelin’s processing of your Personal Information (including making certain decisions about you by processing your Personal Information using automatic means; and depositing and using cookies) is as set out in Ravelin’s privacy policy (available at https://Ravelin.com/) which also contains Ravelin’s contact details for queries.

• Aggregated Information. From time to time, Karhoo may also share anonymized and aggregated information about users of the Karhoo Platform, such as by publishing a report or providing information to our business partners on trends in the usage of the Karhoo Platform and demographic of users.

• Research for university and equivalent level research.

WHERE WE STORE YOUR INFORMATION AND FOR HOW LONG

The information that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by staff operating outside the EEA who work for us or for one of our service providers. These staff may be engaged in the fulfilment of your request, order or reservation, the processing of your payment details and the provision of support services.

Where we transfer Personal Information outside of the EEA, we either transfer Personal Information to countries that provide an adequate level of protection (as determined by the European Commission) or we have appropriate safeguards in place to cover these transfers in the form of standard contractual/data protection clauses adopted by the European Commission or we may rely on Privacy Shield certification, where the data importer is located in the US and has Privacy Shield certification.  Please click here for a link to the standard contractual/data protection clauses and click here for more information about the Privacy Shield for US companies.

If you would like further information, please contact us at privacy@karhoo.com.

We store Personal Information in line with legal, regulatory, financial and good-practice business requirements.

OUR SECURITY PRECAUTIONS

Karhoo uses commercially reasonable physical, electronic and procedural safeguards to protect your Personal Information against loss or unauthorized access, use, modification or deletion but no security program can be guaranteed to be 100% secure.

YOUR RIGHTS

You have the right to ask us not to process your Personal Information for marketing purposes.  If you do not wish to receive marketing communications from Karhoo, please follow the opt-out instructions contained in each such communication or you can stop receiving marketing communications any time by contacting us at privacy@karhoo.com.  Please note that you may not be able to opt-out of certain non-marketing communications about your account or that are necessary to provide the services to you and opting-out of receiving text messages or other communications, as applicable, may impact your use of the Karhoo Platform or may limit Karhoo’s ability to provide services to you.

Please note that it may take up to 30 days for your withdrawal to be reflected in our systems following confirmation of your request to opt-out.  Therefore, you may still receive certain communications during this period.

If you do not want Karhoo to share your Personal Information with third parties for their own direct marketing purposes, you can opt-out of such sharing by going to: http://www.aboutads.info/choices/, http://www.youronlinechoices.eu/ or http://www.networkadvertising.org/understanding-online-advertising.

If you permit the Karhoo Platform to access location services, you can later disable your consent to Karhoo’s further collection of such information at any time by disabling the precise location settings on your mobile device.  If you prefer to prevent third parties from setting and accessing cookies on your computer, you may set your browser to block cookies. Please note that doing so may limit your use of certain features and not all of the tracking tools described in this Privacy Policy will stop.

“DO NOT TRACK” SIGNALS

The Karhoo Platform does not currently respond to “Do Not Track” browser signals as these browser features are not uniform.

ACCESS, EDITING AND DELETING YOUR INFORMATION

Karhoo provides you with the ability to view, update, access, edit and correct your Personal Information. To update your Personal Information, log-into your account.  Our databases automatically update any Personal Information you edit in your profile or that you request we edit. However, Personal Information transmitted through boards, chats, polls or any other means may remain in our databases. We will comply with requests regarding access and/or correction or deletion of the information we store in accordance with applicable law.

If You wish to delete Your account You may do so by emailing us at support@karhoo.com.

You also have a right to: (1) request access your Personal Information, (2) rectify your Personal Information if it is inaccurate or incomplete, (3) obtain erasure of your Personal Information where there is no compelling reason for its continued processing in certain circumstances, (4) obtain restriction of processing of your Personal Information in certain circumstances, (5) object to processing of your Personal Information in certain circumstances, (6) receive your Personal Information provided to us in a structured, commonly used and machine-readable format where our processing of the Personal Information is based on consent or necessity for performance of a contract (to which you are a party) or to take steps at your request prior to entering into such a contract and the processing is carried out by automated means, (7) lodge a complaint with a supervisory authority and (8) object to and not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects or significantly affects you.To exercise any of the rights outlined above in respect of your Personal Information please contact us at privacy@karhoo.com.

Where we have said we process your Personal Information based on consent, you have a right to withdraw your consent at any time by contacting us at privacy@karhoo.com.  This may impact your use of the Karhoo Platform or may limit Karhoo’s ability to provide services to you..

THIRD-PARTY LINKS AND WEBSITES

The Karhoo Platform may contain links to and from the websites of our partner networks, advertisers, affiliates and other third parties (including, but not limited to, websites on which the Karhoo Platform is advertised). If you follow a link to any of these websites, these websites and any services that may be accessible through them have their own privacy policies and this Privacy Policy does not apply.

CHILDREN’S PRIVACY

The Karhoo Platform is not available to minors or users who have had their user account temporarily or permanently deactivated. If we become aware of processing Personal Information of minors, we will delete this information and any relevant account as appropriate.

CONTACT

Questions, comments and requests regarding this Privacy Policy are welcomed and should be addressed to privacy@karhoo.com.  You may also write to us at Karhoo Europe (UK) Limited, Attn. Legal Department, c/o wework 2 Eastbourne Terrace London W2 6LG.