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Ubirider

Rua Alfredo Allen
455/ 461 - sala 1.03

4200-135 Porto

Portugal

Ubirider

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PRIVACY POLICY

 

At Ubirider, S.A. we are committed to optimising your mobility by providing a service that aims to turn urban mobility seamless. However, it is also in our concern the protection of the privacy and personal data of the users of our digital platforms.

 

In this context, in agreement with the transparency principle, we created this Privacy Policy, that is part and should be read together with the terms and conditions of use (available here), and we hope to help you understand how your data is treated, to what ends, for how long, who is it transmitted to and under which security measures.

 

The treatment of data described in this Policy englobes all our digital platforms, including our website and mobile application Pick by Ubirider. By accessing these platforms, some personal information may be solicited, when it is needed to provide a service, when you give express and clear authorisation to do so or when some legal obligation is required.

  1. Who is responsible for the collection and treatment of your personal data?

 

Ubirder S.A., NIPC 514908688, with address in Rua Alfredo Allen, nº 455/461, room 1.03, Paranhos, 4200-135, Porto, Portugal is the entity responsible for the treatment of your personal data collected by your activity as a user. As such, the personal data that you make available will always be managed by this company, which act as the Controller of data treatment, according to the Regulation (EU) 2016/679 of the European Parliament and the Council of 27 of April 2016 - hereby referred to as only GDPR.

 

However, to provide its services, Ubirider S.A. may share you personal data with diverse mobility operators that, in certain situations, may act as Controllers and/or Joint Controllers of data. In light of the referred shared responsibility, agreements are celebrated between the parts in what concerns data protection that transparently define the responsibilities for the fulfilment of the applicable legislation.

 

2. What personal data is going to be asked from you?

 

When using our digital platforms, we request that you share personal data that is needed to provide our service and other data that allow us to enhance your user experience, as it happens in our application. This last personal data is collected when you give us your express and clear consent.

 

In any given case, no more than the necessary information to meet our announced goals and information that allows us to offer the best travel options is required, allying your needs to the ones from the operators.

 

Depending on the means, form and ends for what they are used, when you visit and use our platforms or register, we may request the following data:

 

  1. Key data, such as name, gender, birth date and Tax ID Nº;

  2. Contact information, such as address, email address and phone number

  3. Travel and reservation information, such as number of passengers, booking references and data, trip itinerary, scheduled trips and history of trips;

  4. Geo localisation data, to which our access depends on your previous consent;

  5. Navigation data and preferences, such as navigation data, visited contents, time spent in each content, date and time of access and way of access (mobile, desktop, etc.);

  6. Information collected through the social network from where you started your session, that may include name, gender and profile picture.

 

Finally, Ubirider S.A. will also use your personal data, without identification and in an aggregated way, to transmit to our  partners information related to user’s commercial preferences, but always assuring that the identification of the user is unambiguous impossible.

 

3. For what purpose do we ask and process that data?

 

The personal data that are collected, independently of the platform through which it was made available, will be used, exclusively, for us to provide our service and to pursue the following objectives:

 

  1. For the performance of a contract or prior to entering into a contract” (article 6º, nº1, al. b) of GDPR)

  1. To provide our services, namely to present the best travel option from the mobility operators, according to the criteria selected by the user (fastest, cheapest, etc.);

  2. To issue tickets, manage payments and to issue and send invoices;

  3. Management of complaints and suggestions that may arise from eventual flaws in the provided service;

 

2 For the prosecution of Ubirider, S.A.’s legitimate interests (article 6º, nº1, al. f) of the GDPR):

  1. Fraud prevention;

  2. Managing the relationship with the user, so there is an understanding of how our platforms are used and there can be an improvement of their quality and an optimization of the provided service;

  3. The sending of communications of direct marketing actions, only to our usual clients that Ubirider, S.A. knows well enough to offer to each of them the most tailored services that meet their needs, with the purpose of creating an even more personalized relationship with those clients.

 

3. Processing is also done under your consent (article 6º, nº1, al. a) of the GDPR), for us to provide and pursue the following objectives:

  1. Geo localization data;

  2. Contact information for sending marketing communications to our non-clients;

  3. Contact information for sending our newsletters;

4. When do we ask for that data?

 

Ubirider, S.A. collects your personal data only when it is absolutely necessary and when it has a legitimate reason to do so, always with security and never to different purposes than those stated. This happens when the user access our platforms, registers at our app or fills questionnaires at our website.

 

In fact, the moment that we collects your personal data is variable and depends on concrete circumstances, as the following ones:

4.1. When you create a user's account

 

To create a user’s account and profile, it is necessary to collect some personal data, whether you do it directly at our mobile platform or through a third party social network which you registered with.

4.2. When you use our services

 

We can collect data about the user when our services are used, regarding what you do with them, like your location, your search and trip history, your IP and your future booked trips. The data that the user makes available at this moment is not treated to any other end besides the stated one or any compatible with it, and Ubirider, S.A. commits itself to the privacy and security in the processing and maintenance of each user’s data.

4.3. Suggestions and Complaints

 

If you contact us to send suggestions or complaints, it will be necessary to collect some of your personal data so we can communicate with you and solve the issue.

 

Independently of the subject, we are going to have to keep your identification information and contact in our database, so we can answer you complaint/suggestion.

 

However, when to address your complaint/suggestion, is it necessary to obtain clarification with a mobility operator partner, your data related to said complaint will have to be communicated with this third party entity, whenever possible in an anonymous way.

4.4. Sending of newsletters

 

You can register to receive our newsletter at our website. In this case, and if you give your consent expressly and unmistakably, it will be necessary to collect your email.

4.5. Invoice issue

 

It may be solicited your Tax ID Number if the value of your purchase obligate us, by legal reasons, to issue an invoice with the user’s Tax ID Number.

This personal data may be managed by Ubirider, S.A., or by the mobility operators, according with the conditions contractually established between Ubirider, S.A. and the different mobility operators, namely, according to the responsible entity for the invoice emission or relevant fiscal document for each case.

Whatever the case is, you can always demand that your invoice is issued with your tax ID.

 

5. With whom do we share your personal data?

 

Your data will be kept with Ubirider, S.A. as Controller.

 

However, in certain circumstances, we have to share your personal data with the mobility operators that we work with so we can provide you our services. These entities, however, as Processors or as Joint Controllers of shared data treatment, guarantee the full compliance of the legal parameters of the Privacy and Data Protection. In the cases where these mobility operators act as Joint Controllers, Ubirider, Lda. will reach an agreement with them, in a transparent way, about the purpose and means of data treatment, always complying with the data protection legislation.

 

You can consult the list of mobility operators to which Ubirider, S.A. may transmit your personal data and access the privacy policy of each one (Royal Express).

 

Besides this, Ubirider, S.A. may also resort to services provided by third parties, which ambit relates, all or part of, with the treatment of your personal data. However, these entities will be judiciously selected by Ubirider, S.A. and we will only resort such entities that comply with the requirements imposed by the data protection legislation.

Finally, under the compliance of legal obligations, Ubirider, S.A. may be forced to share your personal data with other entities.

6. Where is my personal data stored?

 

The personal data that you provide to Ubirider, S.A. through its available digital platforms will be stored in servers located in the European Economic Space and also in servers located at third part regions that offer the same kind of data protection that the EU requires, which means that they demonstrate an adequate level of protection. 

To know where your personal data that is transferred to third parties is stored, according to the previous bullet point, you should consult the respective privacy policies.

 

7. For how long is my personal data stored?

 

Ubirider S.A. will keep your personal data stored as long as it is necessary for the ends stated or, when applicable, for the time demanded by law. The conservation limits vary according to the kind of data treated and its finalities, being defined in a case-to-case basis.

 

When the purpose of the data collection is extinguished, and if data is no longer necessary for legal defence of Ubirider, S.A. or third party entities, and/or when there is no legal obligation to keep data, your data will be deleted in a secure way or in an anonymous way.

8. Is your data treated in a safe way?

 

Ubirider, S.A. cares about the security of the personal data that process, implementing the adequate safety, technical, organisational and administrative measures needed to protect the stored data against loss, improper use and/or non authorised access, divulgation, alteration or destruction.

 

Ubirider, S.A. also demands that its Processor’s  and Joint Controllers adopt security measures equivalent to those in practice, namely through the inclusion of secrecy and confidentiality duties in the celebrated agreements.

9. Do we use cookies? What are they and how do we use them?

 

Cookies are small files or bits of software that lodge themselves in the user’s equipment through the used browser and collect information about what is done in each digital platform. There are several types of cookies, more or less intrusive in a way that they collect more or less information, they disclose it to more or less recipients and they are more or less persistent, taking into account the time they stay in the user’s terminal.

 

With effect, like many other operators, we do use cookies with the purpose of improving the performance of our website and the navigation experience, both by accelerating the response given to your interactions  and by not making you introduce your information repeatedly - for example, the user’s details.

 

Summarising, we use our cookies with the following objectives:

  1. Memorize some data that you provide so you do not have to introduce it again, namely for exchanging communication, for sending our newsletter or to remember your registration data;

  2. Make sure that our digital platforms are working properly, enhancing your navigation experience;

  3. Identifying the type of access;

  4. Identifying the geographic location from where the access is coming;

  5. Retain the navigation preferences of our users so we can, in an aggregated way, learn which contents, services and functionalities arise most interest.

 

We also use third party cookies, like Google Analytics, which allow us to understand and register our users behaviours. This service made available by Google allows us to obtain information and evaluate the usage of our users in the present platform, improving their experience. Concretely, it is possible to find out information like, for example, the number of times the user visits our platforms, the duration of those visits or the pages from where the access are made.

 

For more information regarding the configuration of these cookies, we suggest that you consult the following page: https://policies.google.com/technologies/cookies?hl=pt-BR

 

To improve our services, it is also possible that third party tools/plug-ins like Facebook, Instagram or Twitter. These plug-ins allow the user’s browser to establish a direct connection with said social networks, providing access to sharing and additional content. However, since Ubirider, Lda. does not control or have any influence on the contents of said social networks’ plug-ins, we recommend that you obtain more information about the extent of the collection and processing of personal data made by these channels by consulting the privacy policies of said third parties.

 

In the end, if you still do not want your data to be stored through the use of cookies, you should deactivate that functionality here, but keep in mind that that may condition your experience and interaction with the present digital platform.

 

10. What are your rights?

 

The user, has the right to solicit information about his personal data so he can understand what Ubirider, S.A. keeps or knows about him, at any given moment, reasonably and without costs. The right of access, rectification, erasure, object and to restrict processing and portability of your personal data, according to the General Data Protection Regulation (GDPR), can be exercised by changing your profile in the personal area of our mobile platform or through our email hello@ubirider.com.

 

Either way, elimination of your user account as well as withdrawing your consent(s) at our mobile platform only produces effect on it, not being effective concerning other registration or consents given at our website, and vice-versa.

All of these requests will be analysed in a reasonable time period, to which Ubirider, S.A. will promptly respond and, whenever possible, in a maximum of 30 days.

 

The user also has the right to present a complaint to the National Data Protection Commission to the following contacts:

Address: Rua de São Bento, 148 - 3º, 1200-821 Lisboa

Phone Nº: +351 213 928 400

Fax: +351 213 976 832

Email: geral@cnpd.pt

Website: https://www.cnpd.pt/

 

11. Changes to the Privacy Policy

 

The present Privacy Policy can, at any given time and every time deemed necessary, be object of alterations or readjustments. So, even if these alterations are properly published, we recommend that you visit this page regularly to be updated with the most recent version.

December 2019