Privacy Policy
This privacy policy informs you about the nature, scope and purpose of the processing of personal data (hereinafter
referred to as "data") in the context of the provision of our IOS and Android application its functions and content
associated with it (hereinafter collectively referred to as "App").
Our privacy policy is structured as follows:
I. General Information
II. Data processing in our App
III. Our Third Party Providers
IV. Miscellaneous and closing
General Information
What is personal data?
Personal Data is information by which you can be directly or indirectly identified ("Personal Data"). This generally
includes information such as your name, address, email address and telephone number; however, it may also include
other information such as your IP address, shopping habits, lifestyle habits or preferences such as interests.
What is processing?
"Processing" means any operation or set of operations which is performed upon personal data, whether or not by
automatic means. The term is broad and covers virtually any handling of data.
What is the applicable data protection law?
As a Scotland based Company we are bound to follow the UK's Data Protection Act (“DPA”). Since we are however a
company that operates globally we have also adopted the principles set out in the EU's General Data Protection
Regulation (“GDPR”). Given the similarity of both provisions no conflict should arise, but if it does we will follow
the most stringent provision in order to ensure the highest data protection standard available.
Who is the supervisory authority?
The Information Commissioner's Office (ICO) provides advice and information for individuals about protecting
personal information. They also enforce federal privacy laws and are the for us relevant data protection authority.
You can find the ICO's contact details on their website at www.ico.org.uk.
Who is the responsible for processing personal data?
The responsible party within the meaning of the DPA and the GDPR is:
Moon Private Hire Ltd
Great Michael House,
14 Links Place
Edinburgh
EH6 7EZ
Scotland
[email protected]
www.moonprivatehire.co.uk
(hereinafter referred to as "we", "us" or "our")
What are the legal bases of processing personal data?
The legal bases for processing are listed below and at least one of these must apply whenever we process personal
data:
- Consent: the individual has given clear consent to process personal data for a specific purpose.
- Contract: the processing is necessary for a contract or because you have asked us to take specific steps
before entering into a contract.
- Legal obligation: the processing is necessary for us to comply with the law (not including contractual
obligations).
- Vital interests: the processing is necessary to protect someone’s life.
- Public task: the processing is necessary for us to perform a task in the public interest or for official
functions, and the task or function has a clear basis in law.
- Legitimate interests: the processing is necessary for our legitimate interests or the legitimate interests
of a third party, unless there is a good reason to protect your personal data which overrides those
legitimate interests.
What are your rights?
You have the following rights with respect to us processing your personal data:
Data processing in our App
Provision of the app and creation of log files
The legal basis for the processing of your personal data in the context of the provision of the app and the creation
of log files is our legitimate interest. The temporary storage of your personal data by us is necessary to enable
delivery of the App's functionality. For this purpose, your personal data must be stored for the duration of the
session. Data that may be collected when using the App, i.e. IP address, IP location, Geolocation, type and version
of the end device used, information on the mobile network used, time zone settings, operating system and platform.
The storage of your personal data in log files is done to ensure the functionality of the App. In addition, we use
your personal data to optimise the App and to ensure the security of our information technology systems. Your
personal data is not processed in any other way.
Your personal data will be deleted as soon as they are no longer required to achieve the purpose for which they
were collected. In the case of the collection of your personal data for the provision of the App, this is given
as soon as you close the App. In the case of storage of your personal data in log files, these are deleted after
30 days at the latest. If the data is stored beyond this period, your personal data will be anonymised so that
it can no longer be assigned. The collection of your personal data for the provision of the App and the storage
of your personal data in log files is absolutely necessary for the operation of the App. Consequently, there is
no possibility for you to object.
Customer account registration
The legal basis for the processing of your personal data in the context of customer account registration is the
performance of a contract. Your registration enables in particular the conclusion of contracts as well as the
maintenance of our customer relationship. We collect data when you create or update your account and this may
depending on how you use our App.
As a user of our services (“Rider”) this will include your name, email, phone number, login name and password,
address, profile picture, payment or banking information, travel information, time of booking, time of starting
and completing the fare, pick up, drop off location, route taken.
As a provider of services (“Driver”) this will include your name, email, phone number, login name and password,
address, profile picture, payment or banking information, driver’s license and other government identification
documents, birth date, gender, and photo, vehicle or insurance information, emergency contact information, and
evidence of health or fitness to provide services and driver history or criminal record, license status, known
aliases and prior addresses, your right to work in the UK, where applicable, time of starting and completing the
fare, pick up, drop off location, route taken, Private Hire Driver License, Private Hire Vehicle License
V5C Vehicle Logbook and your Certificate of Compliance.
The processing of your personal data within the scope of registration is therefore necessary for the fulfilment
of a contract or the implementation of pre-contractual measures as well as the successful maintenance of our
relationship. Your personal data will be deleted as soon as they are no longer required to achieve the purpose
for which they were collected. This is the case at the latest in the event of the termination of your customer
account. You have the option to cancel your customer account registration at any time. In this case, your
personal data will be deleted unless legal retention periods prevent deletion.
Call feature
During the use of our App, you may use our call feature to contact and call your designated driver or rider. Whilst
the feature will access our devices phone functions and other call related settings and your number is hidden by
default, your personal number will be disclosed to your designated driver or rider upon you using the feature. The
use of the calling feature is entirely optional and the legal basis for processing is as such your consent.
Contact form, feedback form, e-mail and social media contact
The legal basis for the processing of your personal data transmitted in the course of you contacting us is our
legitimate interest. If the contact aims at the conclusion of a contract, the performance of a contract is an
additional legal basis for the processing of your personal data. The processing of your personal data in the event
of a contact serves us solely to process your request.
Your personal data will be deleted as soon as they are no longer required to achieve the purpose for which they
were collected. This is the case for the personal data sent in the course of contacting us when your request has
been processed and legal retention periods do not prevent deletion. You have the option at any time to object to
the processing of your personal data in the context of contacting us for the future. In this case, however, we
will not be able to process your request any further. All personal data stored in the course of contacting you
will be deleted in this case, unless legal retention periods prevent deletion.
Direct marketing
The legal basis for the processing of your personal data in the context of direct marketing measures is either your
consent or our legitimate interest in marketing and promoting our courses and services. The purpose of processing
your personal data in the context of direct marketing measures is to send information, offers and, if applicable, to
promote sales.
Your personal data will be deleted as soon as they are no longer necessary to achieve the purpose for which they
were collected; this is the case in particular upon receipt of the revocation or objection. You can revoke your
consent at any time for the future or object to the processing of your personal data in the context of direct
marketing measures at any time for the future.
When you send a data subject access request
The legal basis for the processing of your personal data in the context of handling your data subject access request
is our legal obligation and the legal basis for the subsequent documentation of the data subject access request is
both our legitimate interest and our legal obligation. The purpose of processing your personal data in the context
of processing data when you send a data subject access request is to respond to your request. The subsequent
documentation of the data subject access request serves to fulfil the legally required accountability.
Your personal data will be deleted as soon as they are no longer required to achieve the purpose for which they
were collected. In the case of the processing of a data subject access request, this is three years after the
end of the respective process. You have the possibility at any time to object to the processing of your personal
data in the context of the processing of a data subject access request for the future. In this case, however, we
will not be able to further process your request. The documentation of the legally compliant processing of the
respective data subject access request is mandatory. Consequently, there is no possibility for you to object.
Legal defence and enforcement of our rights
The legal basis for the processing of your personal data in the context of legal defence and enforcement of our
rights is our legitimate interest. The purpose of processing your personal data in the context of legal defence and
enforcement of our rights is the defence against unjustified claims and the legal enforcement and assertion of
claims and rights.
Your personal data will be deleted as soon as they are no longer necessary to achieve the purpose for which they
were collected. The processing of your personal data in the context of legal defence and enforcement is
mandatory for legal defence and enforcement of our rights. Consequently, there is no possibility for you to
object.
Our Third Party Providers
Firebase
The App uses the
Firebase tool, which is part of the
Firebase platform of Google Inc, 1600 Amphitheatre Parkway Mountain View, CA 94043, USA, to obtain statistics on how
the App is used, in particular active user numbers, session length, stability rating and storage time. Answers logs
the use of the app and we evaluate user behaviour and user activity in general, i.e. not on a personal basis.
For this purpose, the following data is transferred to the Analytics Engine: name and AppStore ID, build version,
individual device installation key (e.g.. IDFA [iOS], Advertising ID, and Android ID), timestamp, device model,
device name, device operating system name and version numbers, the language and country settings of the device
(iOS), the number of CPU cores on the device (iOS), whether a device has the status "jailbreak" (iOS) or "root "
(Android), app lifecycle events (iOS) and app activities (Android);
The legal basis for this data processing is our legitimate interest. The data collected via Google will be
deleted after 6 months at the latest. You can select in the settings under data services whether or not you want
to send data to Google. This setting also applies to the use of Crashlytics.
Crashlytics
The app uses the tool
Crashlytics, which is part of the
platform Firebase of Google Inc., 1600
Amphitheatre Parkway Mountain View, CA 94043, USA, to log crashes of the app. No personal data is transmitted. Only
real-time crash reports with precise details of code locations and device information are sent, which is intended to
simplify maintenance and improve the resulting stability of the app.
The legal basis for data processing is our legitimate interest. In the settings under data services, you can
select whether you want to send crash reports or not. This setting also applies to the use of Google.
Apple Maps (iOS)
For the purposes of map display within our app and for displaying the route preview we use
Apple Maps, a service of Apple Inc. (Infinite Loop, Cupertino, CA
95014, USA; "Apple"). When you use our app, Apple receives the information that you are using our app and
information about your use of the map functions. If you are logged in to Apple, this information is also assigned to
your user account with Apple. If you do not wish this, you must log out of your Apple account before using our app.
The legal basis for the data processing is our legitimate interest. We have no influence on the data collection
and processing by Apple. You can find more information about data processing by Apple in their privacy policy.
Google Maps (Android)
For the purposes of map display within our app and for displaying the route preview, we use Google Maps, a service
of
Google Inc. (1600 Amphitheatre Parkway, Mountain View,
CA 94043, USA; "Google"). When you use our app, Google receives the information that you are using our app as well
as information about your use of the map functions. If you are logged in to Google, this information will also be
assigned to your user account with Google. If you do not wish this, you must log out of your Google account before
using our app. The legal basis for data processing is our legitimate interest. We have no influence on the data
collection and processing by Google.
You can find more information about data processing by Google in their privacy policy.
Online presences in social media
We maintain online presences within social networks and platforms (
Instagram,
Facebook,
Twitter)
in order to be able to communicate with the customers, interested parties and users active there and to inform them
about our services there. When calling up the respective networks and platforms, the terms and conditions and data
processing guidelines of their respective operators apply.
Unless otherwise stated in our privacy policy, we process the data of users if they communicate with us within
the social networks and platforms, e.g. write posts on our online presences or send us messages.
Hosting
The services for hosting and displaying the App are partly provided by our service provider as part of processing on
our behalf. Unless otherwise explained in this privacy policy, all access data and all data collected in forms
provided for this purpose on this APP are processed on their servers. If you have any questions about our service
providers and the basis of our relationship with them, please contact us.
Content Delivery Network
For the purpose of a shorter loading time, we use a so-called Content Delivery Network ("CDN"). With this service,
content, e.g. large media files, are delivered via regionally distributed servers of external CDN service providers.
Therefore, access data is processed on the servers of the service providers. Our service providers work for us
within the framework of order processing. If you have any questions about our service providers and the basis of our
cooperation with them, please contact us.
Miscellaneous and closing
Authorisations and Access
We may request access or permission to certain functions from your mobile device, including camera, contacts,
microphone, reminders, SMS messages, social media accounts, storage, phone calling function and call history etc.
The legal basis for data processing is our legitimate interest and the provision of contractual or
pre-contractual measures. You can deactivate push notifications at any time via Settings/Messages (iOS) or
Settings/Notifications/ (Android).
Push notifications for advertising purposes will only be sent to you if you have given your prior consent. The
legal basis for sending promotional push notifications is consent. Deactivation is also possible via
Settings/Messages (iOS) or Settings/Apps/ (Android).
Transfer of personal data to a third country
In the course of processing your personal data, we may transfer your personal data to trusted and specially selected
service providers in third countries. Third countries are countries that are outside Scotland or the European
Economic Area. In doing so, we only work with service providers who can provide us with suitable guarantees for the
security of your personal data and guarantee that your personal data will be processed in accordance with strict
data protection standards. In the present case, it is not excluded that we transfer data to service providers in the
USA.
Online Payment, Secure data transmission and Credit card information
The transmission of your personal information during an order transaction is encrypted using industry standard
Secure Socket Layer ("SSL") technology, (SSL encryption version 3). Any credit card information you provide will not
be stored by us, but will be encrypted and collected directly from our payment service provider via hypertext
transfer protocol secure ("https").
We may share information with our payment service provider, and you may need to provide credit or debit card
information directly to the provider in order to process payment details and authorise payment following a
secure link. The information which you supply to in such cases is not within our control and is subject to our
payment service provider’s own Privacy Policy and Terms and Conditions.
Security measures
For security reasons and to protect the transmission of content, that you send to us, this site uses SSL or TLS
encryption. You can recognise an encrypted connection by the fact that the address line of the browser changes from
"http://" to "https://" and by the lock symbol in your browser line. If SSL or TLS encryption is activated, the data
you transmit to us cannot be read by third parties.
Obligation to provide personal data
You are not obliged to provide us with personal data. However, depending on the individual case, the provision of
certain personal data may be necessary for the provision of the above services. If you do not provide us with this
personal data, we may not be able to provide the service.
Automated individual decision-making including profiling
We do not make automated decisions in individual cases, including profiling.
Do Not Track
Do Not Track is a privacy preference you can set in most browsers. We support Do Not Track because we believe that
you should have genuine control over how your info gets used and our site responds to Do Not Track requests.
Do Not Sell My Personal Information
We do not sell information that directly identifies you, like your name, address or phone records.
Accuracy
It is important that the data we hold about you is accurate and current, therefore please keep us informed of any
changes to your personal data.
Children Data
Our App is not intended for children and we do not knowingly collect data relating to children. If you become aware
that your Child has provided us with Personal Data, without parental consent, please contact us and we take the
necessary steps to remove that information from our server.
Uninstall
You can stop all information collection by our App by uninstalling it using the standard uninstall process for your
device. If you uninstall the app from your mobile device, the unique identifier associated with your device will
continue to be stored. If you re-install the application on the same mobile device, we will be able to re-associate
this identifier to your previous transactions and activities.
Changes
This policy and our commitment to protecting the privacy of your personal data can result in changes to this policy.
Please regularly review this policy to keep up to date with any changes.
Queries and Complaints
If you have any questions, please do not hesitate to contact us.
