Effective Date: July 1, 2020
COOLNAGOUR LIMITED, trading as iCabbi, is a company incorporated under the laws of Ireland with registered number 484271 and having its registered office at 2nd Floor Offices, SuperValu Building, Sutton Cross, Dublin 13, Ireland (“iCabbi”). We process personal data inside and outside of the EU.
iCabbi operates a cloud-based automated taxi dispatch system for taxi companies and private hire operators (i.e. the Customer). iCabbi’s software system enables taxi companies to deliver a more holistic service to its customers (the Passengers) by providing real time updates to Passengers on taxi arrival times, driver availability, journey statistics and facilitating Passenger feedback.
By providing these services, iCabbi receives personal data relating to the Passengers from its Customers, which may include but is not limited to location, contact details, names and addresses.
This policy describes the data we collect, how it is used and shared, and iCabbi users’ choices regarding how this data is processed. This policy applies to all iCabbi users of our apps, websites, features or other services globally. We recommend that iCabbi users read this along with our Privacy Overview*, which highlights key points about our privacy undertakings as a Data Processor. This policy applies to iCabbi users of ICabbi’s services anywhere in the world, including iCabbi users of ICabbi’s Driver and Passenger Apps, websites, phone systems, Business Insights and other features and services.
This policy applies to:
• Passengers: individuals who request or receive transport from an iCabbi customer
• Drivers: individuals who provide transport for an iCabbi customer
This policy also applies to those who provide data to ICabbi in connection with an application to use the services provided by iCabbi, or whose data ICabbi otherwise receives in connection with its services (such as a passenger of an ICabbi customer making a booking). All the users subject to this policy are referred to as “iCabbi users” within this policy.
The practices described in this policy are subject to applicable laws in the territories where we offer iCabbi products and services
Questions and comments about ICabbi’s data protection practices can be submitted to iCabbi’s Compliance Department (firstname.lastname@example.org).
Data Processor and Independent Controller in Common.
As the provider of, among other elements, a Taxi Dispatch solution, iCabbi processes and stores Personal Data in relation to living individuals, specifically Drivers and Passengers. To that extent, iCabbi acts a Data Processor and has obligations under the Data Protection legislation, which are reflected in this document.
In certain circumstances, iCabbi also will seek to act as a Data Controller, specifically for the purposes of developing and marketing fraud prevention products. iCabbi’s role in this context is as an Independent Controller in Common.
Due to the nature of the services provided by iCabbi there is a regular and active exchange of Personal Data between iCabbi Clients and its data subjects. In addition, iCabbi exchanges Personal Data with data processors on the data subjects’ behalf. This is consistent with iCabbi’s obligations under the terms of its contracts with its data processors.
In accordance with EU Data Protection legislation, this data must be processed fairly and lawfully.
iCabbi is committed to ensuring that all staff members have sufficient awareness of the legislation in order to be able to anticipate and identify a data protection issue, should one arise.
iCabbi processes the following categories of data:
- Data created by our Customers, the transport providers, when they use iCabbi’s products.
- Data that passengers provide to iCabbi when they make a booking with our Customers.
- Data created when passengers use our services, such as location, usage and device data.
- Data from other sources, such as iCabbi partners and third parties that use iCabbi APIs.
What data does iCabbi need to process a booking?
Category of Data Subjects:
Types of Data being Processed:
Purpose of Processing**:
Contact and personal details such as phone number, name, email and location
To facilitate and process bookings and to provide the services
Details of the charity, business, government body or any third party entity with which the passenger is employed, contracted or associated
Details of booking history
To improve the passenger experience
Details of special vehicle requirements
Additional notes regarding the passenger
To improve the passenger experience and the overall quality of the service to the passengers through automated and/or manual processes
Additional Contact details and details of consent provided or not provided
For marketing purposes
Details of driver vehicle and other registration details
To comply with relevant laws and for vetting and record keeping purposes
Payment of any fares owed
To provide the services and for record keeping purposes
Details of fees owed by the driver including equipment rental and booking commissions agreed between the driver and the client.
Details relating to the driver/vehicle location
Details of fares collected by the driver e.g. bookings paid by credit card or by invoice
Details of names of Client employees that will have access to the system for business and/or operational purposes
To facilitate the provision of the services
Data Retention and Deletion
iCabbi retains user profile and other data for as long as iCabbi users maintain their ICabbi account.
iCabbi retains transaction, location, usage and other data for 7 years in connection with regulatory, tax, insurance or other requirements in the places in which it operates. After that period has expired, iCabbi deletes or anonymises the relevant data in accordance with applicable laws.
iCabbi users may request deletion of their accounts and associated personal data at any time. When a user no longer wants to keep their account active, they are invited to email email@example.com. When we receive such requests from a Passenger, we will contact the Taxi Company as they are the Data Controller. We will then delete the information that we don’t need to retain by law (and, for the information that we are required to retain, we will ensure the appropriate protection mechanisms remain).
Data Sharing and Disclosure
iCabbi does not sell or share users’ Personal Data to third parties for third party direct marketing purposes. We share data with our partners in line with best possible practice (including for legal reasons, in connection with claims or disputes, in response to safety concerns etc.)
iCabbi may also share user data other than as described in this policy if users are notified and consent to the sharing in advance.
In the course of its role as Data Processor, iCabbi engages third-party service providers, or third-party data processors, to process Personal Data on its behalf. In each case, a written contract is in place and / or arrangements documents with the sub-processor, outlining their obligations in relation to the Personal Data, the security measures that they must have in place to protect the data, the specific purpose or purposes for which they are engaged, and the understanding that they will only process the data in compliance with the EU Data Protection legislation.
We use multiple iCabbi service providers and business partners to provide our service. A full list of these can be found at: www.icabbi.com/subprocessor
These parties may include, for example:
- Cloud storage providers
- Payment processors
- Marketing partners
- Data analytics providers
- Security partners
- Professional service providers (e.g. privacy advisors, legal firms)
- Fleet partners
- Vehicle solution vendors or third party vehicle suppliers
We may also share our data with law enforcement bodies, government entities or other third parties as necessary to enforce our Terms of Service, user agreements, or other policies, to protect ICabbi’s rights or property or the rights, safety or property of others, or in the event of a claim or dispute relating to their use of our services.
This also includes sharing user data with 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.
General Data Protection Regulation (EU)
To the extent that iCabbi’s use of Personal Data qualifies as ‘business to customer’ processing, including the organisation’s communications to its staff members, the organisation is mindful of its obligations under the relevant EU legislation, namely the General Data Protection Regulation (2016) (“GDPR”). The following key principles are enshrined in EU legislation and are fundamental to iCabbi’s Data Protection Policy.
- Fair, Lawful and Transparent Processing
- Data Minimisation
- Rights of the Data Subject
GDPR requires that companies processing the personal data of EU iCabbi users do so on the basis of specific legal grounds. As described in the table above, **iCabbi processes the data of EU iCabbi users based on one or more of the grounds specified under the GDPR.
Personal Data shall not be transferred to a country or territory outside the EEA unless that country or territory ensures an adequate level of protection for the rights and freedoms of data subjects in relation to the processing of Personal Data. Note that iCabbi’s subsidiary in the US manages and processes its’ Personal Data on a local server.
We may occasionally update this policy. If iCabbi users use our services after an update, iCabbi users consent to the updated policy.
We encourage iCabbi users to periodically review this policy for the latest data on our privacy practices.