Grab Now (trading as Grab Now) (“we”, “our”, “us”) are committed to protecting and respecting your privacy. This policy (together with our terms and condition https://www.grabnow.co.uk/terms, and any other documents referred to in it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By accessing and using our website http://www.grabnow.co.uk/ (“Website”) or by downloading our Grab Now app (“App”) via either Apple’s Appstore or the Google Play Store, you are accepting and consenting to the practices described in this policy.
1. WHO ARE WE?
1.1. Your personal data i.e. any information which identifies you, or which can be identified as relating to you personally, will be collected and used by Skyline Taxi and Private Hire Ltd (trading as Grab Now), a company registered in England with company number 04236992 and registered office at 25 Blundells Road, Bradville, Milton Keynes, England, MK13 7HB.
2.2. This version was last updated on 22nd October 2020. It may change and if it does, these changes will be posted on this page and, where appropriate, notified to you. The new policy may be displayed on-screen and you may be required to read and accept the changes to continue your use of the App or the services on our Website.
2.3. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during our relationship with you.
2.4. Our App or Website may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. Please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services, such as contact and location data. Please check these policies before you submit any personal data to these websites or use these services.
3. THE DATA WE COLLECT ABOUT YOU
3.1. Information you give us. When you provide any details on the Website or to register for an account or download, register and use the App (or contact us in respect of the App or Website), we may collect any or all of the following information about you:
- Personal details (name, address, date of birth, email, postcode, telephone number, mobile number, etc.).
- Personal details and payment details (credit and debit card details etc.).
- Details about payments to and from you and other details of products and services you have purchased from us.
- Your username and password.
- Profile data (purchases, orders, interests, preferences, feedback and survey responses etc.).
We do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
3.2. How we collect data. We use different methods to collect data from and about you including:
- Direct interactions. You may give us your identity, contact and financial data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
o apply for our products or services;
o create an account on our website;
o request marketing to be sent to you;
o enter a competition, promotion or survey; or
o give us feedback or contact us.
- Data we collect automatically. We may collect device identifiers (the internet protocol address used to connect your device to the internet, your log-in information, browser type and version, regional settings, operating system and platform), data about your use of the App and Website, location information (we use GPS technology to determine your current location) and data about your orders (items ordered and the time and date orders are placed) when you access the Website or install and run the App.
4. HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
· Where we need to perform the contract we are about to enter into or have entered into with you.
· Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
· Where we need to comply with a legal obligation.
Generally, we do not rely on consent as a legal basis for processing your personal data. However, you have the right to withdraw consent to marketing at any time by contacting us.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest
To register you as a new customer (a) Identity
(b) Contact Performance of a contract with you
To process and deliver your order including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us (a) Identity
(e) Marketing and Communications (a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include:
(b) Asking you to leave a review or take a survey (a) Identity
(d) Marketing and Communications (a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To enable you to partake in a prize draw, competition or complete a survey (a) Identity
(e) Marketing and Communications (a) Performance of a contract with you
(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (a) Identity
(c) Technical (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you (a) Identity
(e) Marketing and Communications
(f) Technical Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences (a) Technical
(b) Usage Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you (a) Identity
(f) Marketing and Communications Necessary for our legitimate interests (to develop our products/services and grow our business)
To share with third parties we believe will offer goods or services that may be of interest to you (a) Identity
(f) Marketing and Communications Necessary for our legitimate interests (to develop our future marketing strategy and plan product/service development)
We also may share aggregate or anonymous information with third parties, including but not limited to advertisers and investors.
Promotional offers from us
We may use your identity, contact, technical, usage and profile data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving that marketing.
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.
Change of Purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
6. HOW WE PROTECT YOUR PERSONAL DATA
6.1. Technical and organisational measures. All information you provide to us is stored on our secure servers. Any payment transactions carried out by us or our chosen third-party provider of payment processing services will be encrypted using Secured Sockets Layer technology. Where we have given you (or where you have chosen) a password that enables you to access certain parts of our App or Website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone. Once we have received your information, we will use strict procedures and security features to try to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator when we are legally required to do so.
6.2. Device security. You are fully responsible for access to your device. You undertake not to allow unauthorised third parties to use your device for any reason whatsoever. You undertake to contact us as soon as possible should you suspect that an authorised person has gained access to your device. We shall not be held liable for any misuse of your device and any resulting consequences for you, your partner, or any third party.
7. WHO CAN ACCESS YOUR PERSONAL DATA
7.1. We may share personal data with certain third parties including:
• companies in the Skyline Taxi and Private Hire Ltd:
• third parties that support our services;
• any law enforcement or regulatory body, government agency, court or other third party where we believe disclosure is necessary under applicable law or regulations;
• new owners or re-organised entities in the business of restructuring, sale, purchase or joint venture affecting our business; and
• any other person provided that you have not withdrawn your consent above.
However, these activities will be carried out under a contract which imposes strict requirements on our subcontractors or suppliers to keep your information confidential and secure.
8. DATA RETENTION
8.1. Where it is stored. We only store data within the European Economic Area (“EEA”). If our trusted service providers transfer any of it outside of the EEA we will take steps to make sure adequate levels of privacy protection, in line with UK Data Protection Legislation, are in place.
8.2. How long is it stored for (App). The data we collect will be stored and kept for as long as your App remains active. If you delete or remove the App and do not reactivate or access your account for a period of 12 months, your data will be deleted without undue delay. We continually review the personal data we hold and delete what is no longer required.
8.3. How long is it stored for (Website). The data we collect will be shared and kept for as long as your Website Cab-oodle account remains active. If you delete your account and do not reactivate your account within 12 months, your data will be deleted without undue delay. We continually review the personal data we hold and delete what is no longer required.
9. YOUR RIGHTS
We want to ensure you remain in control of your personal data. Part of this is making sure you understand your legal rights, which are as follows:
• the right to confirmation as to whether or not we have your personal data and, if we do, to obtain a copy of it (this is known as a subject access request) within one month of our receiving your request;
• the right to have your data erased (though this will not apply where it is necessary for us to continue to use the data for a lawful reason);
• the right to have inaccurate data rectified;
• the right to object to your data being used for marketing or profiling; and
• where technically feasible, you have the right to see any personal data you have provided to us which we process automatically on the basis of your consent or the performance of a contract. This information will be provided in a common electronic format.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
If you would like further information on your rights or wish to exercise them, please write to us at:
• firstname.lastname@example.org; or
• DPO, 25 Blundells Road, Bradville, Milton Keynes, England, MK13 7HB.
Please keep in mind that there are exceptions to the rights above and, though we will always try to respond to your satisfaction, there may be situations where we are unable to do so. If you are not happy with our response, or you believe that your data protection or privacy rights have been infringed, you should contact the UK Information Commissioner’s Office, which oversees data protection compliance in the UK. Details of how to do this can be found at www.ico.org.uk.