Effective: January 28, 2019
1.2 Data controller
RideHoop Ltd, (“Hoop”, “we”,** “us”, “our”) is the operator of the website www.ridehoop.com (“Website”), the Hoop mobile application(s) (“Application”**) and any other services we provide. Hoop is therefore the data controller of the personal data you provide to us.
1.3 Contact details
1.4 Governing law and jurisdiction
1.5 Effective date
2 What information does Hoop collect?
2.1 Information provided by you
We collect and process personal data about you when you interact with us and our Website/Application, when you register or update your Hoop account, when you purchase or use our services, when we carry out market research, when you subscribe to our e-updates/newsletters, when you contact customer services and when you enter our competitions. This personal data may include, but is not limited to: your name, date of birth, gender, email address, telephone number, login name and password, address, payment or banking information (including related payment verification information), government identification number(s), driver’s license or passport details, photograph and signature, as well as the preferences and settings that you enable for your Hoop account, including marketing preferences.
If we provide online services to a person under the age of 18 where parental consent is required, we may ask for a parent’s email address, in order to ask for consent.
2.2 Information created from using our service
We may generate or collect information about you ourselves. In an online context, much of this is set out in sections 2.4 and 10 below. In an offline context, we may collect information about you through conducting surveys or promotions.
We may collect your precise or approximate location information through data including GPS, IP address, device motion and WiFi of your phone, or GPS location from the Vehicle. We may also collect transaction details related to your use of our services, including the type of services requested and provided, your order details, delivery information, date and time the service was provided, amount charged, distance traveled, and payment method.
Hoop does not collect your payment information such as your credit card number as this is sent directly to our payment provider in encrypted form.
2.3 Information received from third parties
We may also receive information about you from third parties. For example, if you login to our Website/Application using Facebook Connect you will be asked if you wish to share information from your Facebook account with us. Similarly, if you use a “like” or “share” button or feature for our Website/Application on a third party platform, then the third party will share information with us. We may also receive information from third party demographics providers, which we may use to better understand our users and send them appropriate offers and information.
2.4 Information we collect using cookies and other tracking technologies
When you visit our Website/Application, we may collect, process and use information about you and your use of our Website/Application, including your login information, time zone setting, preferred languages, hardware models, IP address, browser plug-in types, software, file names and versions, operating systems and versions, a unique device identifier (e.g. your device’s IMEI number, the MAC address of your device’s wireless network interface or the mobile phone number used by the device), advertising identifiers, serial numbers, mobile network information, a log of your visited pages and how you arrived at our Website/Application. Such information may be collected through “traffic data” and may entail use of “cookies” or other tracking technologies, IP addresses or other numeric codes to identify your computer. For more information on cookies please see section 10 below.
3 How Hoop uses your information
We may process your personal data for the following purposes:
3.1 To fulfil a contract, or take steps linked to a contract: this is relevant where you purchase products or services from us or enter a competition we run and includes:
- verifying your identity;
- taking payments;
- communicating with you;
- administering the competition (where relevant); and
- providing customer services and arranging the delivery or other provision of products, prizes or services.
3.2 As required by us to conduct our business and pursue our legitimate interests, in particular:
- we may use your information to provide products and services you have requested, to respond to any comments or complaints you may send us and to communicate with you about any changes to our policies;
- we may monitor use of our Vehicles, Website, Application and other services we provide (both online and offline) and use your information to help us monitor, improve and protect the same, including (without limitation) providing you with discounts for parking in a Hoop Stop;
- we may use information you provide to personalise our Website, Application, products and services for you, including (without limitation) providing you with reports, recommendations and promotions based on your preferences;
- if you provide credit or debit card details directly to us, we may use third parties to process such payments or check the validity of the payment details you submit in order to prevent fraud;
- we may use security measures to detect, investigate and prevent activities that may violate our policies or be illegal. This is our legal basis for holding any information about you that relates to actual or alleged criminal activity;
- we may use information you provide as well as information which we have collected about you to investigate any complaints received from you or from others, about our Vehicles, Website, Application or our other products and services;
- we may use your data to create anonymous or aggregate information that does not personally identity you, that we can use to perform statistical, demographic and/or marketing analyses of users of our services and their purchasing patterns; and
- we may use data in connection with legal claims, compliance, regulatory and investigative purposes as necessary (including, without limitation, disclosure of such information in connection with legal process or litigation).
3.3 For purposes which are required by law:
- where you exercise your rights under any data protection law and make associated requests;
- where we are required to hold or collect personal data to meet legal requirements incumbent upon us, such as keeping health and safety records, details of purchases or ensuring banned users are not permitted to use our products or services;
- where we need parental consent to provide online services to minors; and
- where in response to requests by government or law enforcement authorities conducting an investigation.
3.4 Where you give us consent:
- we may send you direct marketing in relation to our relevant products and services, or other products and services provided by us and carefully selected partners and sponsors;
- we may place cookies and use similar technologies in accordance with our cookies policy (see section 2.4 above and section 10 below) and the information provided to you when those technologies are used; and
- on other occasions where we ask you for consent, we may use the data for the purpose which we explain at that time.
3.5 Where you give us your explicit consent, when you provide us with personal data about your health, for the following purposes:
- To provide you with tailored services (for example, to accommodate a disability you may have where this is practically possible); and
- To help us investigate an incident which may have taken place involving our Vehicles.
4 Withdrawing consent or otherwise objecting to direct marketing
Wherever we rely on your consent, you will always be able to withdraw that consent, although we may have other legal grounds for processing your data for other purposes, such as those set out above. In some cases, we may send you direct marketing without your consent, where we rely on our legitimate interests. You have an absolute right to opt-out of direct marketing, or profiling we carry out for direct marketing, at any time. You can do this by following the instructions in the communication where this is an electronic message, or by contacting us at firstname.lastname@example.org.
5 Sharing of your personal information
We may share your personal data with other companies in our corporate group.
If you have consented, we may share your personal data with other trusted third parties, for example our commercial partners and the sponsors we work with, so that they can use your personal data for marketing or promotional purposes by sending you information about related products or services that may be of interest to you.
We may also disclose your personal data to third parties in the following circumstances:
- if we sell or buy any business or assets, we may disclose your personal data to the prospective seller or buyer of such business or assets;
- if we (or substantially all of our assets) are acquired by a third party, in which case personal data held by us will be one of the transferred assets;
- if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, any lawful request from government or law enforcement officials, or other competent authorities, and as may be required to meet national security or law enforcement requirements or prevent illegal activity;
- in order to enforce or apply our Terms and Conditions of Use or any other agreement or to respond to any claims, to protect our rights or the rights of a third party, to investigate potential breaches of our policies, to protect the safety of any person or to prevent any illegal activity; or
- to protect the rights, property, or safety of us, our customers or other persons. This may include exchanging personal data with other organisations for the purposes of fraud protection, crime prevention/detection and credit risk reduction.
Save as expressly detailed above in this section, we will never share, sell or rent any of your personal data to any third party without notifying you and/or obtaining your consent.
6 International transfers of your personal data
Your personal data may be transferred to, processed in and stored in a location outside of the European Economic Area (EEA). By submitting your personal data to us, you agree to the transfer, processing and storage of your date in this way.
In particular, your personal data may also be processed by third-party data processors assisting with the provisions of our services to you.
7 Your Rights
You have the right to ask us for a copy of your personal data; to correct, delete or restrict active processing of your personal data; and to obtain the personal data you provide to us for a contract or, with your consent, in a structured, machine-readable format.
In addition, you can object to the processing of your personal data in some circumstances (in particular, where we don’t have to process the data to meet a contractual or other legal requirement, or where we are using the data for direct marketing).
These rights may be limited, for example if fulfilling your request would reveal personal data about another person, where it would infringe the rights of a third party (including our rights) or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping. We will inform you of relevant exemptions we rely upon when responding to any request you make. To exercise any of these rights, you can get in touch with at email@example.com.
You also have a right to lodge a complaint to the applicable supervisory authority or to seek a remedy through the courts.
Data that is mandatory is indicated on relevant forms that you complete. Where provision of data are mandatory, if relevant data are not provided, then we will not be able to fulfil your requests to register, make a purchase or otherwise engage with us. All other provision of your information is optional.
Hoop will normally answer your request within one month. In case of repetitive or unreasonable inquiries, Hoop is entitled to charge a fee.
8 Retention of your personal data
Where we your process data in connection with your registration to use our Website/Application, we do this for as long as you are an active user of our Website/Application and for two (2) years after this.
Where we process your personal data for marketing purposes or with your consent, we process the data until you ask us to stop and for a short period after this (to allow us to implement your requests). We also keep a record of the fact that you have asked us not to send you direct marketing or to process your data indefinitely so that we can respect your request in future.
Where we process your personal data in connection with performing a contract or for a competition, we keep the data for seven (7) years from your last interaction with us or from when the contract ends.
Where we process your personal data to meet legal requirements, we hold this for as long as the law requires.
Where your personal data are held on our systems, then at the end of the retention periods set out above, we will not irrevocably delete your information for another three (3) months – your data will be held in an inactive form for this time to ensure that any consequential links across our systems remain intact in the event that your data are removed in a particular location.
We use all reasonably necessary technical and organisational security measures to protect your data managed by us against manipulation, loss, destruction and against access by unauthorized persons. We are constantly improving our security measures in line with technological development. You must be aware, however, that no method of transmission over the Internet, and no means of electronic or physical storage, is absolutely secure. As such, you acknowledge and accept that we cannot guarantee the security of your information transmitted to, through, or on our Services or via the Internet and that any such transmission is at your own risk and we cannot be held responsible for any unauthorized access by third parties.
10 Cookies and other tracking technologies
Cookies and web beacons are used by us and third parties for the following purposes:
- to enable certain features of our Website/Application (for example, to allow a customer to maintain a basket when they are shopping at an online store);
- to analyse the traffic to our Website/Application (for example, we can count how many people have looked at a specific page, or see how visitors move around our Website/Application when they use it, and use this information to improve our Website/Application);
- to help target advertisements which are more likely to be of interest to you;
- to allow us carry out retargeting (this is when advertisements are presented to you for products or services which you have previously looked at on a Website/Application, but have not purchased); and
- to allow you to interact with our Website/Application on social media platforms.
By accessing our Website/Application from Apple iOS/Android devices, you consent to cookies being stored to your device (and other tracking technologies being used to read data from your device) for the following purposes: keeping you logged in, ensuring that an appropriate version of content is provided, analytics and advertising. Many of these cookies and technologies are essential to the operation of the Website/Application. It is not currently possible to opt out or remove these cookies (or prevent use of these technologies) from the device without deleting the Application.
11 Links to third party websites/applications