Last Updated on 10/02/2021
CHILDREN RELATED DATA COLLECTION
Our Services are applicable to children from 5- 17 years of age. As a user, if you (parent or person authorized by a parent)register a child as a family member (collectively termed as “rider” henceforth), we’ll request that you provide us with certain information (including PII) that can be used to identify such people, such as name, photo, age, phone number, and email address. In the event the user is a child under the age of 13, by providing such information about the child, you affirm that you are such child’s parent or guardian and have all requisite authority to provide us with such information and to authorize us to use such information. In order to provide your Rides and Services, you also acknowledge that, as noted above, we will pass certain of this information on to the Smart-Drivers who provide your Rides and Services. Smart-Drivers will have access to a SmartShuttle-provided phone number to allow the Smart-Drivers to communicate with such users, including riders who are children (however, the user’s actual phone number will not be provided directly to the Smart-Drivers), the rider’s first name and last name, photo, schedule. Smart-Drivers will be able to communicate directly with users, including children under the age of 13, over the course of providing a Ride or Service, via voice call and/or text message, as well as through in-person communication. Other detailed data collection and its use by us is appended below.
INFORMATION DIRECTLY PROVIDED BY USER
SmartShuttle collects information that our users provide directly to us over the web, mobile app, email, phone call or text, or in-person through Smart-Drivers. This information can be collected during various interactions such as when a user creates or modifies their account, request on-demand services, contact customer support, or otherwise communicate with us directly or indirectly. This information may include: name, email, phone number, postal address, profile picture, payment method, service notes, and other information users choose to provide about self or user’s family, friends, and social network (such as about user’s connections, rider’s kids’ school or activity centers/staff, neighbors and their families, etc).
INFORMATION COLLECTED FROM USER’S USE OF OUR SERVICES
When a user uses our Services, SmartShuttle collects information about the user in the following ways:
Location Information: When a user uses SmartShuttle rides and services, SmartShuttle collects precise location data about the rides and services from the SmartShuttle app used by the SmartShuttler. If the user permits the SmartShuttle app to access location services through the permission system used by the user’s mobile operating system (“platform”), SmartShuttle may also collect the precise location of the user’s device when the app is running in the foreground or background. SmartShuttle may also derive the user’s approximate location from the user’s IP address.
Contact Information: If the user permits the SmartShuttle app to access the address book on the user’s device through the permission system used by the user's mobile platform, SmartShuttle may access and store names and contact information from the user's address book to facilitate social interactions through our Services and for other purposes described in this Statement or at the time of consent or collection.
Transaction Information: SmartShuttle collects transaction details related to the user’s use of our Services, including the type of service requested, date and time the service was provided, the amount charged, distance traveled, and other related transaction details. Additionally, if someone uses the user’s promo code, SmartShuttle may associate the user’s name with that person.
Device Information: SmartShuttle may collect information about user’s mobile device, including, for example, the hardware model, operating system and version, software and file names and versions, preferred language, unique device identifier, advertising identifiers, serial number, device motion information, and mobile network information.
Call and SMS Data: Our Services facilitate communications between Users and Smart-Drivers. In connection with facilitating this service, SmartShuttle receives call data, including the date and time of the call or SMS message, the parties’ phone numbers, and the content of the SMS message.
Log Information: When a user interacts with the Services, SmartShuttle collect server logs, which may include information like device IP address, access dates and times, app features or pages viewed, app crashes and other system activity, type of browser, and the third-party site or service user were using before interacting with our Services.
IMPORTANT INFORMATION ABOUT PLATFORM PERMISSIONS
Most mobile platforms (iOS, Android, etc.) have defined certain types of device data that apps cannot access without the user’s consent. And these platforms have different permission systems for obtaining the user's consent. The iOS platform will alert the user the first time the SmartShuttle app wants permission to access certain types of data and will let the user consent (or not consent) to that request. Android devices will notify the user of the permissions that the SmartShuttle app seeks before the user first use the app, and the user’s use of the app constitutes the user’s consent.
INFORMATION SMARTSHUTTLE COLLECT FROM OTHER SOURCES
SmartShuttle may also receive information from other sources and combine that with information SmartShuttle collect through our Services. For example:
If the user chooses to link, create, or log in to the user’s SmartShuttle account with a payment provider (e.g., Google Wallet) or social media services (e.g., Facebook), or if the user engages with a separate app or website that uses our API (or whose API SmartShuttle use), SmartShuttle may receive information about the user or user’s connections from that site or app.
If the user’s affiliation uses one of our enterprise solutions, SmartShuttle may receive information about a user from the user’s affiliate (affiliate can be user’s employee, school, activity centers, etc). When users request SmartShuttle services, our Smart-Drivers may provide us with a rider rating after providing services to riders.
If users also interact with our Services in another capacity, for instance as a Smart-Drivers or user of other apps SmartShuttle provides, SmartShuttle may combine or associate that information with information SmartShuttle has collected from the user in the user’s capacity as a User or rider.
USE OF INFORMATION
SmartShuttle may use the information SmartShuttle collect about a user to:
Provide, maintain, and improve our Services, including, for example, a match between user and Smart-Driver, create pool rides, facilitate payments, send receipts, provide products and services user request (and send related information), develop new features, provide customer support to Users and Smart-Drivers, develop safety features, authenticate users, and send product updates and administrative messages;
Perform internal operations, including, for example, to prevent fraud and abuse of our Services; to troubleshoot software bugs and operational problems; to conduct data analysis, testing, and research; and to monitor and analyze usage and activity trends;
Send or facilitate communications (i) between the user and a Smart-Drivers, such as estimated times of arrival (ETAs), or (ii) between the user and contact of the user at user’s direction in connection with user’s use of certain features, such as referrals, invites, split fare requests, or ETA sharing;
Send user communications SmartShuttle to think will be of interest to users, including information about products, services, promotions, news, and events of SmartShuttle and other companies, where permissible and according to local applicable laws; and to process contest, sweepstake, or other promotion entries and fulfill any related awards;
Personalize and improve the Services, including to provide or recommend features, content, social connections, referrals, and advertisements.
SHARING OF INFORMATION
SmartShuttle may share the information SmartShuttle collect about the user as described in this Statement or as described at the time of collection or sharing, including as follows:
THROUGH OUR SERVICES
SmartShuttle may share user’s information:
With Smart-Drivers to enable them to provide the Services user request. For example, SmartShuttle share rider’s name, photo (if user provide one), average rider rating is given by Smart-Drivers, and pickup and/or drop-off locations with Smart-Drivers;
With other riders, if the user uses a ride-sharing service like Pool ride; and with other people, as directed by the user, such as when the user wants to share the user’s estimated time of arrival or split the fare with a friend;
With third parties to provide the user a service user-requested through a partnership or promotional offering made by a third party or us;
With the general public if the user submit content in a public forum, such as blog comments, social media posts, or other features of our Services that are viewable by the general public;
With third parties with whom user choose to let us share information, for example, other apps or websites that integrate with our API or Services, or those with an API or Service with which SmartShuttle integrate; and
With user’s affiliates (affiliate can be user’s employee, school, activity centers, etc) and any necessary third parties engaged by us or user’s affiliates, if the user participates in any of our enterprise solutions.
OTHER IMPORTANT SHARING
SmartShuttle may share user’s information:
With SmartShuttle subsidiaries and affiliated entities that provide services or conduct data processing on our behalf, or for data centralization and/or logistics purposes;
With vendors, consultants, marketing partners, and other service providers who need access to such information to carry out work on our behalf;
In response to a request for information by a competent authority if SmartShuttle believe disclosure is in accordance with or is otherwise required by any applicable law, regulation, or legal process;
With law enforcement officials, government authorities, or other third parties if SmartShuttle believe user’s actions are inconsistent with our User Agreement, Terms of Service, or policies, or to protect the rights, property, or safety of SmartShuttle or 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;
If SmartShuttle otherwise notify a user and user consent to the sharing; and
In an aggregated and/or anonymized form which cannot reasonably be used to identify the user.
SOCIAL SHARING FEATURES
The Services may integrate with social sharing features and other related tools which let users share actions users take on our Services with other apps, sites, or media, and vice versa. The user’s use of such features enables the sharing of information with the user’s friends or the public, depending on the settings the user establishes with the social sharing service. Please refer to the privacy policies of those social sharing services for more information about how they handle the data users provide to or share through them.
ANALYTICS AND ADVERTISING SERVICES PROVIDED BY OTHERS
“Web Beacons” (also known as clear gifs) are tiny graphics with a unique identifier that may be included on our Services for several purposes, including to deliver or communicate with Cookies, to track and measure the performance of our Services, to monitor how many visitors view our Services, and to monitor the effectiveness of our advertising. Unlike Cookies, which are stored on the user’s hard drive, Web Beacons are typically embedded invisibly on web pages (or in an email).
Users may correct user’s account information at any time by logging into the user’s online or in-app account. If the user wishes to cancel the user's account, please email us at email@example.com. Please note that in some cases SmartShuttle may retain certain information about users as required by law, or for legitimate business purposes to the extent permitted by law. For instance, if the user has a standing credit or debt on the user’s account, or if SmartShuttle believes the user has committed fraud or violated our Terms, SmartShuttle may seek to resolve the issue before deleting the user’s information.
SmartShuttle will comply with individual requests regarding access, correction, and/or deletion of the personal data it stores in accordance with applicable law.
SmartShuttle requests permission for our app’s collection of precise location from the user’s device per the permission system used by the user’s mobile operating system. If the user initially permits the collection of this information, the user can later disable it by changing the location settings on the user’s mobile device. However, this will limit the user's ability to use certain features of our Services. Additionally, disabling our app’s collection of precise location from user’s device will not limit our ability to collect user’s trip location information from a SmartShuttler's device nor our ability to derive approximate location from user’s IP address.
SmartShuttle may also seek permission for our app’s collection and syncing of contact information from the user’s device per the permission system used by the user’s mobile operating system. If users initially permit the collection of this information, iOS users can later disable it by changing the contacts settings on the user’s mobile device. The Android platform does not provide such a setting.
Users may opt-out of receiving promotional messages from us by following the instructions in those messages. If users opt-out, SmartShuttle may still send users non-promotional communications, such as those about the user’s account, about the Services the user has requested, or our ongoing business relations.
SmartShuttler (Service Provider) Side
SmartShuttle collects information about SmartShuttlers (drivers, care providers, couriers, partner transportation companies, and any other persons that use the SmartShuttle platform under license (collectively referred to as “SmartShuttlers,” or individually “you”) when a SmartShuttler uses our mobile applications, websites, and other online products and services (collectively, the “Services”) and through other interactions and communications you have with us.
SCOPE AND APPLICATION
This Smart-Driver Privacy Statement (“Statement”) applies to Smart-Drivers (drivers, care providers, couriers, partner transportation companies, and any other persons that use the SmartShuttle platform under license (collectively referred to as “Smart-Drivers,” or individually “you”) and reside in Qatar. If you interact with the Services as both a User and a Smart-Driver, the respective privacy statements apply to your different interactions.
COLLECTION OF INFORMATION
SmartShuttle may collect personal data from you during the course of your application for, and use of, the SmartShuttle Services, including location data, which information may be stored, processed, and/or accessed by SmartShuttle, as well as its service providers, for business purposes, including for marketing, lead generation, service development and improvement, analytics, industry and market research, and such other purposes consistent with SmartShuttle’s and its Affiliates’ legitimate business needs. By submitting information to SmartShuttle during the application process and/or by using the Services, you consent to such collection and use of personal data.
DISCLOSURE OF SMARTSHUTTLER INFORMATION TO THIRD PARTIES
Subject to all applicable laws, SmartShuttle may provide to a third party any information (including personal data and any SmartShuttle Data) about Smart-Drivers provided hereunder if: (a) there is a complaint, dispute or conflict, including an accident, relating to a Smart-Driver; (b) it is necessary to enforce the terms of the Agreement; (c) it is required, in SmartShuttle’s sole discretion, by applicable law, regulation, ordinance, license, or operating agreement; (d) it is necessary, in SmartShuttle’s sole discretion, to protect the safety, rights, property, or security of SmartShuttle, the SmartShuttle Services, or any third party; to detect, prevent or otherwise address fraud, security or technical issues; and/or to prevent or stop the activity which SmartShuttle, in its sole discretion, considers to be, or to pose a risk of being, illegal, unethical, or legally actionable.
LOCATION-BASED SERVICES CONSENT
You hereby expressly consent to SmartShuttle’s use of location-based services and expressly waive and release SmartShuttle from any and all liability, claims, causes of action, or damages arising from your use of the SmartShuttle Services, or in any way relating to the use of the precise location and other location-based services.
CHANGES TO THE STATEMENT
SmartShuttle may change this Statement from time to time. If SmartShuttle makes significant changes in the way SmartShuttle treat user’s personal information, or to the Statement, SmartShuttle will provide user notice through the Services or by some other means, such as email. User’s continued use of the Services after such notice constitutes user’s consent to the changes. SmartShuttle encourages users to periodically review the Statement for the latest information on our privacy practices.
If users have any questions about this Privacy Statement, please contact us at +974 50902111 or email us at firstname.lastname@example.org or write us at # Al Gassar Tower, 7th Floor, Doha, Qatar.