Privacy Policy | Travelo Services

TRAVELO SERVICES

Version: 1.0

Effective Date: to be confirmed

Last Updated: to be confirmed

1. INTRODUCTION

1.1 Purpose of this Privacy Policy

Travelo Services (”Travelo Services”, “we”, “our”, or “us”) is committed to protecting the privacy, confidentiality, integrity and security of all personal data entrusted to us.

This Privacy Policy explains how we collect, use, disclose, store, protect, retain and otherwise process personal data whenever you use or interact with the Travelo Services website, mobile applications, booking platform, customer support services or any related products and services.

This Privacy Policy has been prepared to provide transparency regarding our processing of personal information and to comply with applicable data protection legislation in every jurisdiction in which Travelo Services operates.

We recognise that privacy is a fundamental right and are committed to processing all personal data lawfully, fairly, transparently and securely.

This Privacy Policy applies whether you are a passenger, driver, fleet operator, corporate customer, website visitor, mobile application user, prospective customer or any other individual whose personal data is processed by Travelo Services.

By accessing or using any Travelo Services service, website or application, you acknowledge that you have read and understood this Privacy Policy.

Nothing contained within this Privacy Policy limits or excludes any statutory rights available to you under applicable law.

1.2 Our Commitment to Privacy

Travelo Services is committed to maintaining the highest standards of privacy protection and information security.

We implement appropriate administrative, organisational, contractual, physical and technical safeguards designed to protect personal data against accidental or unlawful destruction, accidental loss, unauthorised disclosure, unauthorised access, misuse, alteration, corruption or any other unlawful processing.

Privacy considerations are integrated throughout the design, development and operation of our website, mobile applications, payment systems, customer support operations and internal management systems.

We continually review and improve our privacy practices to reflect technological developments, cybersecurity risks, changes in legislation and recognised industry best practices.

1.3 Who This Privacy Policy Applies To

This Privacy Policy applies to all individuals interacting with Travelo Services, including but not limited to:

(a)Passengers;
(b)Registered customers;
(c)Prospective customers;
(d)Licensed private hire drivers;
(e)Prospective drivers;
(f)Fleet operators;
(g)Corporate and business account holders;
(h)Authorised users of corporate accounts;
(i)Visitors to our website;
(j)Users of our mobile applications;
(k)Individuals contacting customer support;
(l)Participants in promotions, competitions or referral programmes;
(m)Individuals submitting complaints, enquiries or feedback;
(n)Individuals involved in investigations, disputes or regulatory enquiries;
(o)Individuals whose personal data is supplied by another user in connection with a booking; and
(p)Any other individual whose personal data is processed in connection with the operation of the Travelo Services platform.

1.4 About Our Services

Travelo Services operates a technology platform that enables passengers to arrange transportation with licensed private hire drivers through digital booking systems.

Depending upon the jurisdiction in which our services are provided, the Platform may include:

Passenger accounts;
Driver accounts;
Fleet operator accounts;
Corporate and business accounts;
Driver bidding functionality;
Automatic driver allocation;
Instant bookings;
Scheduled bookings;
Airport transfers;
Stripe card pre-authorisation;
Apple Pay;
Google Pay;
Credit and debit card payments;
Digital wallet functionality;
Driver wallet services;
Driver payouts;
One-Time Password (OTP) verification;
GPS navigation and route management;
Live location sharing where enabled;
Emergency panic button functionality;
Journey history;
Ratings and reviews;
Promotional offers and discount codes;
Referral programmes;
Customer support services;
Fraud prevention systems;
Identity verification procedures;
Driver licence verification;
Payment dispute management;
Lost property assistance;
Marketing communications;
Cookies and similar technologies;
Website and application analytics;
Cybersecurity monitoring; and
Additional products, services and features introduced from time to time.

1.5 Applicable Privacy Laws

Travelo Services processes personal data in accordance with all applicable data protection legislation, including where relevant:

(a)The United Kingdom General Data Protection Regulation (“UK GDPR”);
(b)The Data Protection Act 2018;
(c)Regulation (EU) 2016/679 (General Data Protection Regulation) as applicable within Member States of the European Union, including Malta;
(d)Applicable privacy and data protection legislation in Pakistan;
(e)Applicable electronic communications legislation;
(f)Consumer protection legislation;
(g)Payment services legislation;
(h)Anti-money laundering legislation where applicable;
(i)Transportation licensing legislation; and
(j)Any other applicable laws governing the collection, processing, storage or disclosure of personal information.

Where legal requirements differ between jurisdictions, Travelo Services will process personal data in accordance with the laws applicable to the relevant jurisdiction.

2. DEFINITIONS

For the purposes of this Privacy Policy, the following words and expressions shall have the meanings set out below unless the context requires otherwise.

2.1 “Account”

Means any registered passenger account, driver account, fleet operator account, corporate account or other registered user account created on the Travelo Services Platform.

2.2 “Applicable Law”

Means all legislation, regulations, statutory instruments, regulatory guidance, codes of practice and legally binding governmental requirements relating to privacy, data protection, electronic communications, payment services, transportation services and consumer protection applicable to Travelo Services.

2.3 “Booking”

Means any transportation request submitted through the Travelo Services Platform, whether accepted, rejected, cancelled, completed or otherwise processed.

2.4 “Controller”

Means the legal person or organisation that determines the purposes and means of processing personal data.

Unless otherwise stated, Travelo Services acts as the Data Controller for the personal data described in this Privacy Policy.

2.5 “Corporate Account”

Means a business account that enables an organisation and its authorised personnel to arrange transportation through the Travelo Services Platform.

2.6 “Customer”

Means any passenger, account holder or authorised individual using the Travelo Services Platform.

2.7 “Data Processor”

Means any natural or legal person that processes personal data on behalf of Travelo Services under a written contractual agreement.

2.8 “Driver”

Means a licensed private hire driver registered on the Travelo Services Platform for the purpose of receiving and completing transportation bookings.

2.9 “Fleet Operator”

Means any business or organisation managing one or more licensed drivers or vehicles through the Travelo Services Platform.

2.10 “Personal Data”

Means any information relating to an identified or identifiable natural person, including information capable of identifying an individual directly or indirectly.

Personal data includes, without limitation, names, postal addresses, email addresses, telephone numbers, payment information, location information, identification documents, photographs, device identifiers, online identifiers and any other information capable of identifying an individual.

2.11 “Platform”

Means the Travelo Services website, passenger mobile application, driver mobile application, fleet management systems, corporate booking portal, administrative systems, APIs, customer support systems and all associated digital infrastructure operated by or on behalf of Travelo Services.

2.12 “Processing”

Means any operation or set of operations performed upon personal data, whether by automated means or otherwise, including collection, recording, organisation, structuring, storage, adaptation, alteration, retrieval, consultation, use, disclosure, transmission, dissemination, alignment, combination, restriction, erasure or destruction.

2.13 “Sensitive Personal Data”

Means personal data that receives additional legal protection under applicable law, including where applicable:

(a)biometric information;
(b)health information;
(c)racial or ethnic origin;
(d)religious or philosophical beliefs;
(e)trade union membership;
(f)genetic information;
(g)criminal offence information where lawfully processed; and
(h)any other category of personal data recognised as sensitive under applicable legislation.

Travelo Services will only process Sensitive Personal Data where permitted or required by applicable law.

2.14 “Services”

Means all transportation-related services, booking facilities, payment services, digital wallet services, customer support services, websites, mobile applications and associated technology platforms provided by Travelo Services.

2.15 “User”

Means any individual accessing, browsing, registering for or otherwise using the Platform, whether as a passenger, driver, fleet operator, corporate customer or website visitor.

3. SCOPE OF THIS PRIVACY POLICY

3.1 General Scope

This Privacy Policy governs the collection, use, disclosure and protection of personal data processed by Travelo Services through the provision of its Services.

It applies regardless of whether personal data is collected directly from you, automatically through your use of the Platform or indirectly through authorised third parties.

3.2 Activities Covered

This Privacy Policy applies to personal data processed through:

(a)the Travelo Services website;
(b)passenger mobile applications;
(c)driver mobile applications;
(d)fleet operator platforms;
(e)corporate booking portals;
(f)customer support services;
(g)telephone communications;
(h)email correspondence;
(i)live chat facilities;
(j)online enquiry forms;
(k)booking systems;
(l)payment systems;
(m)digital wallet services;
(n)driver wallet services;
(o)referral programmes;
(p)promotional campaigns;
(q)surveys and customer feedback;
(r)identity verification procedures;
(s)driver onboarding;
(t)regulatory compliance procedures;
(u)fraud prevention systems;
(v)cybersecurity monitoring systems; and
(w)any future products or services introduced by Travelo Services.

3.3 Territorial Scope

This Privacy Policy applies to personal data processed in connection with Travelo Services’ operations within:

(a)the United Kingdom;
(b)Malta;
(c)Pakistan; and
(d)any additional jurisdiction in which Travelo Services lawfully provides its Services.

Where local legislation provides additional rights or obligations, Travelo Services shall comply with those legal requirements in addition to this Privacy Policy.

3.4 Third-Party Services

Our Platform may contain links to third-party websites, applications or services.

Travelo Services is not responsible for the privacy practices, content, security or policies of third-party organisations that operate independently from Travelo Services.

Users are encouraged to review the privacy policies of all third-party services before providing personal information to those organisations.

3.5 Services Outside Our Control

This Privacy Policy does not apply to:

(a)independent websites operated by third parties;
(b)payment providers acting as independent Data Controllers;
(c)independent transportation services arranged outside the Travelo Services Platform;
(d)third-party advertising networks;
(e)social media platforms;
(f)government services;
(g)banking institutions; or
(h)any organisation processing personal data under its own privacy policy.

4. ABOUT TRAVELO SERVICES

4.1 Company Information

Travelo Services operates a digital transportation platform designed to connect passengers with licensed private hire drivers through secure online booking technology.

Our Platform supports transportation services for private individuals, businesses, fleet operators and corporate customers while providing secure payment processing, journey management and customer support.

4.2 Company Details

Company Name:

Travelo Services

Location:

Wirral, United Kingdom

Website:

https://traveloservices.com

Support Email:

support@traveloservices.com

4.3 Our Role

For the majority of personal data described in this Privacy Policy, Travelo Services acts as the Data Controller.

Where another organisation determines the purposes and means of processing personal data, that organisation shall act as the independent Data Controller and its own privacy policy shall apply.

Where Travelo Services processes personal data solely on behalf of another organisation, Travelo Services shall act as a Data Processor and process such information only in accordance with documented instructions and applicable law.

5. DATA CONTROLLER

5.1 Identity of the Data Controller

Unless expressly stated otherwise, the Data Controller responsible for the processing of your personal data is:

Travelo Services

Location:

Wirral, United Kingdom

Email:

support@traveloservices.com

5.2 Responsibilities of the Data Controller

Travelo Services is responsible for determining:

(a)why personal data is collected;
(b)how personal data is processed;
(c)how long personal data is retained;
(d)who personal data is shared with;
(e)how personal data is protected;
(f)how individuals may exercise their privacy rights; and
(g)compliance with applicable privacy legislation.

6. CONTACT DETAILS FOR PRIVACY ENQUIRIES

Questions regarding this Privacy Policy or the processing of your personal data may be directed to:

Travelo Services

Privacy Team

Location:

Wirral, United Kingdom

Email:

support@traveloservices.com

Travelo Services will endeavour to acknowledge privacy enquiries promptly and respond within the timeframes required by applicable law.

7. DATA PROTECTION PRINCIPLES

Travelo Services processes personal data in accordance with the following principles.

7.1 Lawfulness, Fairness and Transparency

Personal data shall only be processed where there is a lawful basis for doing so.

Processing activities will be carried out fairly, transparently and in accordance with applicable legislation.

7.2 Purpose Limitation

Personal data shall be collected only for specified, explicit and legitimate purposes.

Personal data will not be processed for purposes incompatible with those originally communicated unless permitted by law.

7.3 Data Minimisation

Travelo Services will collect only the personal data that is reasonably necessary for the provision of its Services, compliance with legal obligations, prevention of fraud and protection of legitimate business interests.

Excessive or unnecessary personal data will not be intentionally collected.

7.4 Accuracy

Reasonable steps will be taken to ensure that personal data remains accurate, complete and up to date.

Where inaccurate information is identified, Travelo Services will take appropriate steps to correct or update such information without undue delay.

7.5 Storage Limitation

Travelo Services will retain personal data only for as long as is reasonably necessary to fulfil the purposes for which it was collected, to comply with applicable legal, regulatory, tax, accounting and licensing obligations, to resolve disputes, enforce contractual rights or protect our legitimate business interests.

Where personal data is no longer required, it will be securely deleted, anonymised or otherwise disposed of using appropriate technical and organisational measures.

Further details regarding retention periods are provided in Section 39 of this Privacy Policy.

7.6 Integrity and Confidentiality

Travelo Services implements appropriate technical and organisational security measures designed to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, unauthorised access or any other unlawful form of processing.

Security measures are regularly reviewed and updated to address emerging threats, technological developments and changes in applicable legislation.

7.7 Accountability

Travelo Services accepts responsibility for complying with applicable data protection legislation and maintains policies, procedures and governance arrangements designed to demonstrate ongoing compliance.

Where required by law, appropriate records of processing activities shall be maintained.

8. INTERPRETATION

8.1 Headings

Headings and titles are included for convenience only and shall not affect the interpretation of this Privacy Policy.

8.2 Singular and Plural

Words importing the singular shall include the plural and vice versa where the context permits.

8.3 Gender

References to any gender shall include every other gender.

8.4 References to Legislation

References to legislation include any amendments, replacements, re-enactments or successor legislation.

8.5 Severability

If any provision of this Privacy Policy is found to be unlawful, invalid or unenforceable, the remaining provisions shall continue in full force and effect.

9. GENERAL PROVISIONS

9.1 Good Faith

Travelo Services is committed to processing personal data honestly, fairly and transparently while respecting the privacy rights of all individuals.

9.2 Privacy by Design

Privacy and data protection considerations are incorporated into the design, development, implementation and operation of the Travelo Services Platform.

Where reasonably practicable, privacy risks are assessed before introducing new products, services or technologies.

9.3 Privacy by Default

Systems operated by Travelo Services are designed so that only personal data necessary for a particular purpose is processed.

Where appropriate, privacy-enhancing settings are enabled by default.

9.4 Continuous Improvement

Travelo Services continually reviews and improves its privacy practices, cybersecurity measures and internal procedures to maintain compliance with applicable legislation and recognised industry standards.

10. CATEGORIES OF PERSONAL DATA WE COLLECT

The categories of personal data collected depend upon how you interact with the Travelo Services Platform, the services you use and the legal obligations applicable to your account.

Travelo Services may collect the following categories of personal data.

10.1 Identity Information

Identity information may include:

(a)Full name;
(b)Previous names where required;
(c)Date of birth;
(d)Gender where voluntarily provided or legally required;
(e)Nationality where required for regulatory purposes;
(f)Profile photograph;
(g)Government-issued identification details;
(h)Passport information where required;
(i)Driving licence information;
(j)National identity card details where applicable;
(k)User account identification numbers;
(l)Customer reference numbers;
(m)Driver identification numbers;
(n)Fleet operator identification numbers; and
(o)Any other information necessary to verify identity or comply with legal obligations.

10.2 Contact Information

We may collect:

(a)Residential address;
(b)Correspondence address;
(c)Billing address;
(d)Email address;
(e)Mobile telephone number;
(f)Alternative contact numbers;
(g)Emergency contact details where voluntarily provided;
(h)Business contact information;
(i)Corporate contact information; and
(j)Preferred communication methods.

10.3 Account Information

Account information may include:

(a)Username;
(b)Password (stored in encrypted form);
(c)Account preferences;
(d)Language preferences;
(e)Notification preferences;
(f)Marketing preferences;
(g)Communication preferences;
(h)Accessibility settings;
(i)Security settings;
(j)Login history;
(k)Account status;
(l)Account verification status; and
(m)Records of account updates.

10.4 Booking Information

Travelo Services may collect information relating to every booking, including:

(a)Pickup location;
(b)Destination;
(c)Intermediate stops;
(d)Booking date and time;
(e)Scheduled pickup time;
(f)Journey duration;
(g)Distance travelled;
(h)Vehicle category requested;
(i)Number of passengers;
(j)Booking reference numbers;
(k)Booking status;
(l)Cancellation information;
(m)Cancellation reasons;
(n)Waiting time;
(o)Additional charges;
(p)Driver allocation information;
(q)Driver bidding information where applicable;
(r)Booking modifications; and
(s)Special instructions submitted by users.

10.5 Payment Information

Where payment services are used, we may process information including:

(a)Payment method;
(b)Transaction reference numbers;
(c)Payment authorisation details;
(d)Stripe transaction identifiers;
(e)Card pre-authorisation records;
(f)Apple Pay transaction information;
(g)Google Pay transaction information;
(h)Wallet balances;
(i)Driver wallet balances;
(j)Refund records;
(k)Promotional discounts;
(l)Voucher information;
(m)Payment dispute information;
(n)Chargeback information;
(o)Billing history; and
(p)Financial transaction records.

For security reasons, Travelo Services does not intentionally store complete payment card numbers or card security codes where these are securely processed by PCI-DSS compliant payment providers.

10.6 Location Information

Depending upon your device settings and the services used, Travelo Services may process:

(a)Real-time GPS location;
(b)Pickup location;
(c)Destination location;
(d)Live driver location;
(e)Journey route;
(f)Navigation information;
(g)Approximate device location;
(h)Historical journey locations;
(i)Location timestamps;
(j)Route optimisation information; and
(k)Location sharing preferences.

Location information may continue to be processed during active journeys for operational, safety, fraud prevention and customer support purposes.

10.7 Device Information

When you access the Platform, we may automatically collect certain technical information, including:

(a)Device model;
(b)Operating system;
(c)Device manufacturer;
(d)Browser type;
(e)Browser version;
(f)Mobile application version;
(g)Device identifiers;
(h)IP address;
(i)Mobile network information;
(j)Language settings;
(k)Time zone;
(l)Crash reports;
(m)Diagnostic information;
(n)Performance information;
(o)Application usage statistics; and
(p)Security-related device information.

10.8 Communication Information

Travelo Services may collect and process information relating to communications made through or in connection with the Platform, including:

(a)Customer support enquiries;
(b)Telephone conversations where lawfully recorded;
(c)Email correspondence;
(d)Live chat communications;
(e)In-app messages;
(f)Complaint records;
(g)Feedback submissions;
(h)Survey responses;
(i)Lost property enquiries;
(j)Safety reports;
(k)Emergency assistance requests;
(l)Communications relating to payment disputes;
(m)Driver support requests; and
(n)Communications with regulatory authorities where applicable.

Communications may be retained for quality assurance, training, fraud prevention, legal compliance and dispute resolution purposes.

10.9 Driver Information

Where you register as a driver, Travelo Services may collect additional personal information including:

(a)Driver licence details;
(b)Driver licence expiry dates;
(c)Private hire licence details;
(d)Licensing authority information;
(e)Driver badge information;
(f)National insurance information where required;
(g)Right to work documentation where applicable;
(h)Insurance documentation;
(i)Vehicle ownership information;
(j)Driver profile photographs;
(k)Driver ratings;
(l)Driver performance metrics;
(m)Driver availability;
(n)Driver wallet information;
(o)Driver payout information;
(p)Driver compliance records;
(q)Driver training records where applicable;
(r)Identity verification records; and
(s)Regulatory compliance information.

10.10 Vehicle Information

Travelo Services may collect information relating to vehicles operating through the Platform, including:

(a)Vehicle registration number;
(b)Vehicle make;
(c)Vehicle model;
(d)Vehicle colour;
(e)Year of manufacture;
(f)Seating capacity;
(g)Vehicle licence details;
(h)Vehicle insurance information;
(i)MOT or roadworthiness information where applicable;
(j)Vehicle inspection records;
(k)Accessibility features;
(l)Vehicle photographs;
(m)Vehicle ownership details;
(n)Vehicle compliance documentation; and
(o)Any additional information required by licensing authorities.

10.11 Corporate Account Information

Where bookings are made through a corporate or business account, we may process:

(a)Company name;
(b)Registered business address;
(c)Company registration number;
(d)VAT number where applicable;
(e)Authorised users;
(f)Business email addresses;
(g)Business telephone numbers;
(h)Billing information;
(i)Purchase order references;
(j)Internal cost centre information;
(k)Employee travel records;
(l)Booking authorisations; and
(m)Corporate payment arrangements.

10.12 Fleet Operator Information

Fleet operators may provide information including:

(a)Business name;
(b)Fleet operator licence information;
(c)Registered business address;
(d)Fleet management details;
(e)Driver allocation information;
(f)Fleet vehicle information;
(g)Fleet payment information;
(h)Fleet performance information;
(i)Compliance records; and
(j)Fleet administrator contact details.

10.13 Verification Information

To protect users and comply with legal obligations, Travelo Services may collect information used for identity verification, including:

(a)Photographic identification documents;
(b)Selfie verification images;
(c)Facial comparison results where permitted by law;
(d)Proof of address documentation;
(e)Driver licence verification records;
(f)Vehicle licence verification records;
(g)Insurance verification records;
(h)Business verification documentation;
(i)Right to work documentation where required; and
(j)Verification status records.

Verification information is collected solely for legitimate operational, regulatory, fraud prevention and security purposes.

10.14 Safety Information

Travelo Services may collect information relating to user safety, including:

(a)Emergency contact information voluntarily provided;
(b)Panic Button activations;
(c)Emergency assistance requests;
(d)Incident reports;
(e)Safety complaints;
(f)Driver misconduct reports;
(g)Passenger misconduct reports;
(h)Investigation records;
(i)Lost property reports;
(j)Safety follow-up records; and
(k)Communications with emergency services where necessary.

10.15 Marketing Information

Where permitted by law, we may process:

(a)Marketing preferences;
(b)Communication preferences;
(c)Newsletter subscriptions;
(d)Promotional campaign participation;
(e)Referral programme participation;
(f)Promotional code usage;
(g)Competition entries;
(h)Prize redemption records; and
(i)Marketing consent records.

10.16 Technical Information

Our systems may automatically collect technical information including:

(a)Application logs;
(b)Server logs;
(c)Error reports;
(d)API usage information;
(e)Authentication records;
(f)Login timestamps;
(g)Session identifiers;
(h)Security event logs;
(i)Device authentication information;
(j)Cookie identifiers;
(k)Browser identifiers;
(l)Operating system information;
(m)Network diagnostics;
(n)Internet Protocol (IP) addresses;
(o)Device performance information; and
(p)System configuration information.

10.17 Usage Information

Travelo Services analyses how users interact with the Platform in order to improve our Services.

Usage information may include:

(a)Features accessed;
(b)Buttons selected;
(c)Search activity;
(d)Booking behaviour;
(e)Navigation patterns;
(f)Session duration;
(g)Pages viewed;
(h)Screen interactions;
(i)Frequency of use;
(j)Preferred booking methods;
(k)Favourite destinations where saved by the user;
(l)App settings used; and
(m)General interaction with Platform features.

10.18 Cookies and Online Identifiers

When you use our website or mobile applications, we may collect information through cookies and similar technologies, including:

(a)Cookie identifiers;
(b)Session identifiers;
(c)Device identifiers;
(d)Browser identifiers;
(e)Advertising identifiers;
(f)Analytics identifiers;
(g)Preference cookies;
(h)Authentication cookies;
(i)Security cookies; and
(j)Other technologies used to improve the functionality, security and performance of our Platform.

Further information regarding cookies is provided later within this Privacy Policy.

10.19 Information Received from Third Parties

Travelo Services may receive personal information from authorised third parties, including:

(a)Payment service providers;
(b)Identity verification providers;
(c)Driver licence verification providers;
(d)Vehicle licensing authorities;
(e)Fleet operators;
(f)Corporate account administrators;
(g)Customer referral partners;
(h)Regulatory authorities;
(i)Law enforcement agencies where legally authorised;
(j)Insurance providers;
(k)Fraud prevention agencies;
(l)Cloud service providers; and
(m)Other organisations where permitted or required by applicable law.

10.20 Information You Choose to Provide

You may voluntarily provide additional information when using our Services, including:

(a)Accessibility requirements;
(b)Medical assistance requests relevant to transportation;
(c)Special travel instructions;
(d)Preferred routes;
(e)Driver feedback;
(f)Passenger feedback;
(g)Profile photographs;
(h)Additional contact information;
(i)Communication preferences; and
(j)Any other information you voluntarily submit while using the Platform.

You should avoid providing unnecessary personal information or sensitive personal data unless specifically requested or required for the provision of our Services.

11. HOW WE COLLECT PERSONAL DATA

Travelo Services collects personal data through a variety of methods depending upon your interaction with our Platform.

The methods by which personal data is collected are explained below.

11.1 Information You Provide Directly

We collect personal data that you voluntarily provide when you:

(a)Create an account;
(b)Make a booking;
(c)Register as a driver;
(d)Register as a fleet operator;
(e)Register a corporate account;
(f)Contact customer support;
(g)Submit identification documents;
(h)Verify your identity;
(i)Add payment methods;
(j)Participate in promotions;
(k)Refer another user;
(l)Complete surveys;
(m)Leave ratings or reviews; or
(n)Otherwise communicate with Travelo Services.

11.2 Information Collected Automatically

When you access or use the Platform, certain information is automatically collected through our systems, applications and security technologies.

This may include technical information, device information, location information, usage information, cookies, analytics information and security logs necessary for the operation, maintenance and protection of our Services.

11.3 Information Collected from Third Parties

Travelo Services may receive personal data from authorised third parties where this is necessary for the provision of our Services or required by law.

Such third parties may include:

(a)Payment service providers;
(b)Stripe and associated payment processing partners;
(c)Apple Pay;
(d)Google Pay;
(e)Identity verification providers;
(f)Driver licence verification providers;
(g)Vehicle licensing authorities;
(h)Fleet operators;
(i)Corporate account administrators;
(j)Insurance providers;
(k)Fraud prevention agencies;
(l)Credit reference agencies where legally permitted;
(m)Government authorities;
(n)Regulatory bodies;
(o)Law enforcement agencies;
(p)Cloud hosting providers;
(q)Customer referral partners; and
(r)Other organisations authorised to share information under applicable law.

Where information is obtained from third parties, Travelo Services will process such information only where there is a lawful basis for doing so.

11.4 Information Collected Through Your Use of the Platform

As you use the Platform, we automatically collect information relating to your interaction with our Services.

This information assists us in providing bookings, improving system performance, maintaining security, preventing fraud and complying with legal obligations.

Information collected may include:

(a)Journey activity;
(b)Booking history;
(c)Device activity;
(d)Login history;
(e)Application usage;
(f)GPS location during active journeys;
(g)Network information;
(h)Device diagnostics;
(i)Crash reports;
(j)Security event logs;
(k)Wallet activity;
(l)Payment activity; and
(m)Communications with our Platform.

11.5 Information Generated During Your Use of Our Services

Certain personal data is created as a result of your use of Travelo Services.

Examples include:

(a)Ride history;
(b)Driver ratings;
(c)Passenger ratings;
(d)Booking preferences;
(e)Wallet balances;
(f)Payment history;
(g)Cancellation history;
(h)Driver acceptance rates;
(i)Journey receipts;
(j)Customer support records;
(k)Investigation records;
(l)Referral rewards;
(m)Promotional activity; and
(n)Account security records.

11.6 Information Required by Law

Certain information is collected because Travelo Services is legally required to obtain, verify or retain it.

Examples include:

(a)Driver licence information;
(b)Vehicle licensing information;
(c)Insurance documentation;
(d)Identity verification documentation;
(e)Tax-related information where required;
(f)Regulatory reporting information;
(g)Anti-fraud verification records; and
(h)Information required by licensing authorities.

Failure to provide mandatory information may prevent Travelo Services from providing certain Services.

12. LAWFUL BASES FOR PROCESSING PERSONAL DATA

Travelo Services processes personal data only where there is a lawful basis for doing so under applicable data protection legislation, including the UK GDPR, EU GDPR and other relevant laws.

Depending upon the circumstances, one or more lawful bases may apply simultaneously.

12.1 Performance of a Contract

We process personal data where such processing is necessary to perform a contract with you or to take steps prior to entering into a contract.

Examples include:

(a)Creating user accounts;
(b)Processing bookings;
(c)Allocating drivers;
(d)Facilitating driver bidding;
(e)Processing payments;
(f)Managing digital wallets;
(g)Providing customer support;
(h)Sending booking confirmations;
(i)Processing cancellations;
(j)Issuing receipts;
(k)Processing refunds;
(l)Managing driver payouts; and
(m)Providing all other services requested by users.

Without this processing, Travelo Services would be unable to provide its transportation platform.

12.2 Compliance with Legal Obligations

Travelo Services processes personal data where required to comply with applicable legal obligations.

These obligations may include:

(a)Transportation licensing laws;
(b)Tax legislation;
(c)Financial reporting obligations;
(d)Anti-money laundering legislation;
(e)Fraud prevention requirements;
(f)Court orders;
(g)Regulatory investigations;
(h)Law enforcement requests;
(i)Consumer protection legislation;
(j)Payment services regulations;
(k)Data protection legislation; and
(l)Other legal obligations applicable to Travelo Services.

12.3 Legitimate Interests

Travelo Services processes personal data where such processing is necessary for our legitimate interests or those of a third party, provided such interests are not overridden by your rights and freedoms.

Our legitimate interests include:

(a)Operating and improving the Platform;
(b)Preventing fraud;
(c)Detecting suspicious activity;
(d)Protecting users;
(e)Maintaining cybersecurity;
(f)Providing customer support;
(g)Improving service quality;
(h)Developing new products and services;
(i)Conducting internal administration;
(j)Protecting legal rights;
(k)Recovering debts;
(l)Managing business operations;
(m)Preventing abuse of the Platform;
(n)Investigating complaints;
(o)Managing disputes;
(p)Conducting internal audits;
(q)Monitoring system performance;
(r)Analysing service usage;
(s)Maintaining platform stability; and
(t)Protecting Travelo Services, its users and the wider public.

Where we rely upon legitimate interests, we will balance those interests against your privacy rights before processing your personal data.

In certain circumstances, Travelo Services relies upon your consent before processing personal data.

Examples include:

(a)Certain marketing communications;
(b)Optional cookies;
(c)Promotional notifications;
(d)Referral programmes where required by law;
(e)Optional location services beyond those required to provide the Service;
(f)Optional profile information; and
(g)Any other processing requiring consent under applicable legislation.

Where processing is based upon consent, you may withdraw your consent at any time.

Withdrawal of consent will not affect the lawfulness of processing carried out before consent was withdrawn.

12.5 Vital Interests

Travelo Services may process personal data where necessary to protect the vital interests of an individual.

Examples include:

(a)Responding to emergency situations;
(b)Panic Button activations;
(c)Contacting emergency services;
(d)Sharing location information during emergencies;
(e)Protecting passengers or drivers from imminent harm; and
(f)Responding to serious safety incidents.

12.6 Public Interest

Where authorised or required by law, Travelo Services may process personal data in the public interest.

This may include:

(a)Assisting regulatory authorities;
(b)Cooperating with law enforcement agencies;
(c)Supporting public safety initiatives;
(d)Preventing criminal activity;
(e)Responding to public health emergencies where required by law; and
(f)Other processing authorised by applicable legislation.

12.7 Multiple Lawful Bases

In many circumstances, more than one lawful basis may apply to the same processing activity.

For example, processing payment information may be necessary both for the performance of a contract and for compliance with legal obligations relating to financial record keeping.

Travelo Services will rely upon the most appropriate lawful basis for each processing activity in accordance with applicable legislation.

13. PASSENGER DATA PROCESSING

Travelo Services processes passenger information for the purpose of providing safe, reliable and efficient transportation services.

Passenger data processing is limited to what is necessary for the operation of the Platform, compliance with legal obligations and protection of users.

13.1 Passenger Registration

When creating a passenger account, Travelo Services may collect:

(a)Full name;
(b)Email address;
(c)Mobile telephone number;
(d)Password;
(e)Account preferences;
(f)Communication preferences;
(g)Marketing preferences;
(h)Referral information where applicable; and
(i)Any additional information voluntarily provided by the passenger.

13.2 Passenger Verification

To improve platform security and reduce fraud, Travelo Services may verify passenger information using:

(a)One-Time Password (OTP) verification;
(b)Email verification;
(c)Mobile number verification;
(d)Device verification;
(e)Payment verification;
(f)Identity verification where necessary; and
(g)Other verification methods introduced to enhance platform security.

13.3 Booking Management

Travelo Services processes passenger information to facilitate and manage transportation bookings.

This processing includes:

(a)Receiving booking requests;
(b)Identifying pickup and destination locations;
(c)Calculating estimated fares;
(d)Offering available driver options;
(e)Operating the driver bidding system where applicable;
(f)Automatically allocating drivers where applicable;
(g)Confirming bookings;
(h)Monitoring journey progress;
(i)Managing booking amendments;
(j)Processing cancellations;
(k)Generating electronic receipts;
(l)Maintaining booking history; and
(m)Providing customer support throughout the booking process.

13.4 Passenger Communications

Travelo Services may communicate with passengers regarding:

(a)Booking confirmations;
(b)Driver arrival notifications;
(c)OTP verification codes;
(d)Journey updates;
(e)Booking cancellations;
(f)Payment confirmations;
(g)Safety alerts;
(h)Lost property enquiries;
(i)Customer support responses;
(j)Service announcements;
(k)Regulatory notifications where required;
(l)Changes to our Services; and
(m)Updates to our legal documentation.

These communications may be delivered through the mobile application, SMS, telephone calls, email or push notifications depending upon your account preferences and the nature of the communication.

13.5 Passenger Journey History

Travelo Services maintains records relating to completed and cancelled journeys.

Journey history may include:

(a)Pickup location;
(b)Destination;
(c)Journey route;
(d)Date and time of travel;
(e)Driver details;
(f)Vehicle details;
(g)Fare charged;
(h)Discounts applied;
(i)Payment method;
(j)Journey duration;
(k)Distance travelled;
(l)Booking reference number;
(m)Ratings submitted; and
(n)Customer support records relating to that journey.

Journey history enables passengers to review previous bookings, obtain receipts, recover lost property, resolve disputes and improve future booking experiences.

13.6 Passenger Ratings and Reviews

Passengers may voluntarily provide ratings and reviews regarding drivers and completed journeys.

Travelo Services may use these ratings to:

(a)Maintain service quality;
(b)Improve driver performance;
(c)Investigate complaints;
(d)Detect fraudulent activity;
(e)Reward high-performing drivers;
(f)Identify training requirements; and
(g)Improve overall customer satisfaction.

Ratings and reviews must be submitted honestly and must not contain unlawful, abusive, discriminatory or defamatory content.

13.7 Passenger Support Services

Where passengers contact Travelo Services, we may process personal information to:

(a)Respond to enquiries;
(b)Resolve complaints;
(c)Investigate incidents;
(d)Recover lost property;
(e)Resolve payment issues;
(f)Investigate safety concerns;
(g)Provide technical assistance;
(h)Improve customer service; and
(i)Comply with legal obligations.

Support interactions may be recorded, monitored or retained for quality assurance, training, fraud prevention, legal compliance and dispute resolution purposes where permitted by applicable law.

14. DRIVER DATA PROCESSING

Drivers play a critical role in the provision of our Services.

Accordingly, Travelo Services processes driver information to facilitate lawful, safe and efficient transportation services.

14.1 Driver Registration

When registering as a driver, Travelo Services may collect:

(a)Full legal name;
(b)Residential address;
(c)Email address;
(d)Mobile telephone number;
(e)Date of birth;
(f)Driver profile photograph;
(g)Driver licence details;
(h)Private hire licence details;
(i)Licensing authority information;
(j)National Insurance number where required by law;
(k)Right to work documentation where applicable;
(l)Insurance information;
(m)Vehicle information;
(n)Banking details for payouts;
(o)Emergency contact information where voluntarily provided; and
(p)Other information reasonably required for driver onboarding.

14.2 Driver Identity Verification

Before permitting drivers to operate on the Platform, Travelo Services may carry out identity verification procedures.

Verification may include:

(a)Government-issued photographic identification;
(b)Driver licence verification;
(c)Licence status verification;
(d)Proof of address verification;
(e)Vehicle documentation checks;
(f)Insurance verification;
(g)Licensing authority verification;
(h)Facial comparison technology where legally permitted;
(i)Selfie verification;
(j)Manual document review; and
(k)Ongoing compliance monitoring.

Travelo Services reserves the right to refuse, suspend or terminate driver accounts where verification cannot be satisfactorily completed or maintained.

14.3 Driver Compliance

Travelo Services processes driver information to ensure continuing compliance with applicable legislation and licensing requirements.

This may include monitoring:

(a)Driver licence validity;
(b)Private hire licence validity;
(c)Vehicle licence validity;
(d)Insurance expiry dates;
(e)Vehicle inspection records;
(f)Regulatory compliance;
(g)Driver account standing;
(h)Complaints history;
(i)Safety incidents; and
(j)Driver performance.

Drivers are responsible for ensuring that all information provided remains accurate and up to date.

14.4 Driver Availability

Travelo Services processes driver availability information in order to:

(a)Allocate bookings;
(b)Operate the bidding system;
(c)Display available drivers to passengers;
(d)Calculate estimated arrival times;
(e)Improve service efficiency;
(f)Balance supply and demand;
(g)Optimise dispatch systems; and
(h)Improve customer experience.

14.5 Driver Performance Information

Travelo Services may process information relating to driver performance, including:

(a)Booking acceptance rates;
(b)Booking completion rates;
(c)Cancellation rates;
(d)Passenger ratings;
(e)Customer feedback;
(f)Complaint records;
(g)Journey completion statistics;
(h)Punctuality;
(i)Safety records;
(j)Platform activity;
(k)Driver response times; and
(l)Compliance history.

Driver performance information may be used to maintain service quality, improve customer experience, provide driver support and ensure compliance with applicable policies.

14.6 Driver Wallet

Where the Driver Wallet feature is available, Travelo Services may process information including:

(a)Wallet balance;
(b)Commission deductions;
(c)Booking earnings;
(d)Bonuses;
(e)Incentive payments;
(f)Referral rewards;
(g)Promotional payments;
(h)Wallet adjustments;
(i)Manual credits;
(j)Manual deductions;
(k)Withdrawal requests;
(l)Transaction history; and
(m)Wallet statements.

Driver Wallet information is maintained for operational, accounting, regulatory and auditing purposes.

14.7 Driver Payouts

Travelo Services processes payment information necessary to facilitate driver payouts.

This may include:

(a)Bank account details;
(b)Payment processor information;
(c)Payout history;
(d)Payment references;
(e)Settlement reports;
(f)Transaction confirmations;
(g)Tax-related payment records where required; and
(h)Financial reconciliation information.

Payouts are processed using secure payment providers and appropriate financial safeguards.

14.8 Driver Communications

Travelo Services may communicate with drivers regarding:

(a)Booking opportunities;
(b)Booking confirmations;
(c)Bid notifications;
(d)Passenger updates;
(e)Licensing reminders;
(f)Insurance reminders;
(g)Regulatory changes;
(h)Platform updates;
(i)Service announcements;
(j)Payment notifications;
(k)Driver support enquiries;
(l)Safety notices; and
(m)Emergency communications.

15. FLEET OPERATOR DATA PROCESSING

15.1 Fleet Operator Registration

Where a Fleet Operator registers to use the Platform, Travelo Services may collect personal and business information including:

(a)Business name;
(b)Trading name where applicable;
(c)Registered business address;
(d)Company registration number where applicable;
(e)VAT registration number where applicable;
(f)Fleet operator licence information;
(g)Primary contact details;
(h)Authorised administrator details;
(i)Business email addresses;
(j)Business telephone numbers;
(k)Payment information;
(l)Driver allocation information; and
(m)Any additional information reasonably required to administer fleet services.

15.2 Fleet Management

Travelo Services processes fleet operator information to:

(a)Register fleet accounts;
(b)Manage fleet vehicles;
(c)Allocate drivers;
(d)Manage driver access;
(e)Process fleet bookings;
(f)Monitor service quality;
(g)Produce operational reports;
(h)Process payments;
(i)Investigate complaints;
(j)Comply with licensing requirements; and
(k)Maintain platform security.

15.3 Fleet Communications

Travelo Services may communicate with Fleet Operators regarding:

(a)Driver management;
(b)Vehicle compliance;
(c)Regulatory updates;
(d)Booking activity;
(e)Payment information;
(f)Platform updates;
(g)Safety notices;
(h)Customer complaints;
(i)Operational reports; and
(j)Account administration.

16. CORPORATE ACCOUNT DATA PROCESSING

16.1 Corporate Accounts

Travelo Services offers business and corporate transportation services.

Where a Corporate Account is created, we may process information relating to:

(a)The business;
(b)Authorised employees;
(c)Corporate administrators;
(d)Booking permissions;
(e)Billing arrangements;
(f)Approved payment methods;
(g)Company travel policies;
(h)Internal booking references;
(i)Cost centres;
(j)Department codes;
(k)Employee travel records; and
(l)Corporate reporting requirements.

16.2 Corporate Booking Management

Corporate information is processed to:

(a)Arrange employee transportation;
(b)Manage authorised users;
(c)Process business payments;
(d)Produce invoices;
(e)Generate management reports;
(f)Maintain booking records;
(g)Investigate complaints;
(h)Prevent fraudulent bookings;
(i)Comply with contractual obligations; and
(j)Improve business travel services.

16.3 Corporate Communications

Travelo Services may communicate with Corporate Account administrators regarding:

(a)Account management;
(b)Employee bookings;
(c)Billing enquiries;
(d)Service updates;
(e)Platform improvements;
(f)Security notifications;
(g)Regulatory information;
(h)Contract renewals; and
(i)Customer support.

17. IDENTITY VERIFICATION

17.1 Purpose of Identity Verification

Travelo Services may verify the identity of passengers, drivers, fleet operators and corporate users where necessary to:

(a)Prevent fraud;
(b)Protect users;
(c)Comply with legal obligations;
(d)Verify eligibility to use the Platform;
(e)Maintain platform security;
(f)Prevent identity theft;
(g)Detect unauthorised account access; and
(h)Maintain trust within the Platform.

17.2 Verification Methods

Identity verification may include:

(a)Email verification;
(b)Mobile telephone verification;
(c)One-Time Password (OTP) verification;
(d)Government-issued identification documents;
(e)Passport verification where required;
(f)Driver licence verification;
(g)Proof of address;
(h)Selfie verification;
(i)Facial comparison technology where legally permitted;
(j)Manual verification by authorised personnel; and
(k)Verification performed by trusted third-party providers.

17.3 Refusal of Verification

Where identity verification cannot be completed satisfactorily, Travelo Services reserves the right to:

(a)Refuse account registration;
(b)Restrict account functionality;
(c)Suspend services;
(d)Delay payments;
(e)Prevent bookings;
(f)Request additional documentation; or
(g)Permanently close the account where appropriate and permitted by law.

18. DRIVER LICENCE AND VEHICLE VERIFICATION

18.1 Driver Licence Verification

Travelo Services verifies driver licensing information to ensure compliance with applicable transportation legislation.

Verification may include:

(a)Driver licence validity;
(b)Licence expiry dates;
(c)Driver entitlement categories;
(d)Licensing authority records;
(e)Private hire licence status;
(f)Endorsements where legally accessible;
(g)Suspension information where lawfully available; and
(h)Other regulatory information required by law.

18.2 Vehicle Verification

Vehicle verification may include:

(a)Vehicle registration details;
(b)Vehicle ownership;
(c)Vehicle licensing;
(d)Insurance verification;
(e)MOT or roadworthiness status where applicable;
(f)Vehicle inspections;
(g)Accessibility compliance;
(h)Vehicle photographs;
(i)Vehicle age;
(j)Vehicle category; and
(k)Other documentation required by licensing authorities.

18.3 Ongoing Compliance

Travelo Services may periodically request updated documentation to ensure that drivers and vehicles continue to satisfy applicable legal and regulatory requirements.

Failure to provide updated documentation may result in temporary suspension or permanent removal from the Platform.

19. PAYMENT INFORMATION PROCESSING

19.1 General Payment Processing

Travelo Services processes payment information to facilitate secure transportation transactions.

Depending upon the payment method selected, payment processing may involve authorised third-party payment providers operating under their own regulatory obligations.

19.2 Payment Methods

The Platform may support:

(a)Credit cards;
(b)Debit cards;
(c)Stripe payment services;
(d)Apple Pay;
(e)Google Pay;
(f)Digital Wallet payments;
(g)Driver Wallet transactions;
(h)Corporate billing arrangements;
(i)Promotional credits; and
(j)Other payment methods introduced by Travelo Services.

19.3 Payment Security

Travelo Services implements appropriate safeguards designed to protect payment information.

Sensitive payment information is processed using secure payment technologies and industry-recognised security standards.

Where payment processing is carried out by third-party payment providers, those providers remain responsible for protecting payment information processed within their own systems.

19.4 Fraud Prevention

Payment information may be analysed to detect:

(a)Unauthorised transactions;
(b)Suspicious payment activity;
(c)Fraudulent bookings;
(d)Chargeback abuse;
(e)Stolen payment methods;
(f)Multiple account abuse;
(g)Unusual transaction patterns; and
(h)Other activities presenting financial or security risks.

Where suspicious activity is identified, Travelo Services may delay, suspend or refuse transactions while appropriate investigations are undertaken.

20. STRIPE CARD PRE-AUTHORISATION

20.1 Purpose of Card Pre-Authorisation

Where supported, Travelo Services uses Stripe card pre-authorisation to verify that a passenger’s selected payment method is valid and capable of covering the estimated cost of a journey.

Card pre-authorisation helps to:

(a)Reduce payment failures;
(b)Prevent fraudulent transactions;
(c)Confirm payment method validity;
(d)Improve driver payment security;
(e)Reduce chargeback risks;
(f)Improve booking reliability; and
(g)Protect passengers and drivers from failed payment transactions.

20.2 Nature of a Pre-Authorisation

A pre-authorisation is not an immediate charge.

Instead, a temporary authorisation may be placed against the passenger’s payment method for an amount determined by Travelo Services or our payment provider.

The authorised amount may differ from the final fare.

20.3 Adjustment of Authorised Amounts

Where applicable, the authorised amount may be adjusted before completion of the journey to reflect changes including:

(a)Additional stops;
(b)Waiting time;
(c)Route changes;
(d)Fare adjustments;
(e)Toll charges;
(f)Parking charges;
(g)Airport fees;
(h)Additional passenger requests; and
(i)Other charges properly incurred during the journey.

20.4 Final Payment Capture

Following completion of the journey, Travelo Services or its authorised payment provider may capture the final amount due based upon:

(a)The agreed fare;
(b)Applicable commissions;
(c)Waiting time;
(d)Additional stops;
(e)Toll charges;
(f)Parking charges;
(g)Airport charges;
(h)Promotional discounts;
(i)Wallet credits;
(j)Refund adjustments; and
(k)Any other applicable fees disclosed to the passenger.

20.5 Failed Authorisations

Where payment authorisation cannot be successfully completed, Travelo Services reserves the right to:

(a)Refuse the booking;
(b)Request an alternative payment method;
(c)Restrict account functionality;
(d)Suspend wallet facilities;
(e)Delay booking confirmation; or
(f)Take any other reasonable action necessary to protect the Platform.

21. APPLE PAY AND GOOGLE PAY

21.1 Supported Digital Payment Methods

Travelo Services may support payment through Apple Pay, Google Pay and other authorised digital payment services.

Availability may vary depending upon jurisdiction, device compatibility and payment provider requirements.

21.2 Digital Wallet Processing

When Apple Pay or Google Pay is used:

(a)Travelo Services does not receive your full payment card number;
(b)Payment credentials are securely tokenised by the relevant payment provider;
(c)Transactions are processed through secure payment infrastructure;
(d)Payment authentication is managed by the payment provider; and
(e)Travelo Services receives only the information necessary to complete the transaction.

21.3 Third-Party Terms

Use of Apple Pay, Google Pay or similar services remains subject to the privacy policies, terms and conditions of the relevant provider.

Travelo Services encourages users to review those policies before using such payment methods.

22. DIGITAL WALLET

22.1 Passenger Digital Wallet

Where available, Travelo Services may provide passengers with a Digital Wallet to facilitate payments and account management.

The Digital Wallet may contain:

(a)Promotional credits;
(b)Referral rewards;
(c)Refund credits;
(d)Account balances;
(e)Booking credits;
(f)Promotional vouchers; and
(g)Other credits issued by Travelo Services.

22.2 Wallet Transactions

The Digital Wallet may record:

(a)Credits;
(b)Debits;
(c)Booking payments;
(d)Refunds;
(e)Promotional awards;
(f)Referral rewards;
(g)Expiry of promotional balances;
(h)Manual adjustments; and
(i)Other authorised transactions.

22.3 Wallet Security

Travelo Services implements appropriate safeguards to protect wallet balances and transaction records.

Users remain responsible for maintaining the confidentiality of their account credentials.

Unauthorised access resulting from compromised passwords or devices should be reported immediately.

22.4 Wallet Restrictions

Travelo Services reserves the right to:

(a)Suspend wallet functionality;
(b)Restrict wallet usage;
(c)Reverse fraudulent transactions;
(d)Correct accounting errors;
(e)Remove improperly obtained credits;
(f)Investigate suspicious wallet activity; and
(g)Close wallet facilities where necessary to protect the Platform or comply with legal obligations.

23. DRIVER WALLET

23.1 Purpose

Where the Driver Wallet feature is available, Travelo Services maintains records relating to driver earnings and authorised deductions.

23.2 Driver Wallet Records

Driver Wallet information may include:

(a)Booking earnings;
(b)Company commission;
(c)Promotional incentives;
(d)Referral rewards;
(e)Bonus payments;
(f)Manual adjustments;
(g)Refund deductions where applicable;
(h)Wallet balance;
(i)Withdrawal history;
(j)Pending payouts;
(k)Transaction references; and
(l)Account statements.

23.3 Accuracy of Wallet Records

Drivers should regularly review Driver Wallet records.

Any discrepancies should be reported promptly through the customer support process.

Travelo Services will investigate genuine discrepancies and make corrections where appropriate.

24. DRIVER PAYOUTS

24.1 Payment Processing

Driver earnings may be transferred using authorised payment providers.

Travelo Services processes only the information reasonably necessary to complete authorised payouts.

24.2 Payout Information

Information processed may include:

(a)Bank account details;
(b)Account holder name;
(c)Payment references;
(d)Payout amount;
(e)Settlement date;
(f)Transaction status;
(g)Currency;
(h)Payment provider reference; and
(i)Other information necessary to complete the payout.

24.3 Payment Delays

Travelo Services reserves the right to delay payouts where reasonably necessary to:

(a)Investigate fraud;
(b)Resolve disputes;
(c)Comply with legal obligations;
(d)Complete identity verification;
(e)Verify banking information;
(f)Correct accounting discrepancies; or
(g)Protect the Platform from financial risk.

25. PAYMENT DISPUTE INVESTIGATIONS

25.1 Investigation of Payment Disputes

Travelo Services may investigate payment disputes involving passengers, drivers, payment providers or financial institutions.

Investigations may include review of:

(a)Booking records;
(b)GPS information;
(c)Journey history;
(d)Payment records;
(e)Customer support communications;
(f)Driver information;
(g)Passenger information;
(h)Receipts;
(i)System logs;
(j)Device information;
(k)Fraud indicators; and
(l)Other relevant evidence.

Where necessary, Travelo Services may share relevant information with:

(a)Payment providers;
(b)Banks;
(c)Card issuers;
(d)Fraud prevention agencies;
(e)Law enforcement authorities;
(f)Regulatory authorities;
(g)Insurance providers;
(h)Legal advisers; and
(i)Other authorised organisations where legally permitted or required.

Only information reasonably necessary for the investigation shall be disclosed.

25.3 Chargebacks

Where a payment is subject to a chargeback, Travelo Services may retain and use relevant records for the purpose of:

(a)Responding to the chargeback;
(b)Investigating fraud;
(c)Protecting legal rights;
(d)Recovering financial losses;
(e)Preventing repeated abuse of the Platform; and
(f)Complying with applicable financial regulations.

26. ONE-TIME PASSWORD (OTP) VERIFICATION

26.1 Purpose of OTP Verification

Travelo Services uses One-Time Password (“OTP”) verification to enhance the security of user accounts and reduce the risk of fraud.

OTP verification helps us to:

(a)Verify account ownership;
(b)Confirm telephone numbers;
(c)Authenticate users during account registration;
(d)Verify identity during account recovery;
(e)Prevent unauthorised account access;
(f)Improve platform security;
(g)Protect payment transactions; and
(h)Comply with applicable regulatory requirements.

26.2 When OTP Verification May Be Used

OTP verification may be required when:

(a)Creating an account;
(b)Logging into the Platform from a new device;
(c)Resetting a password;
(d)Updating contact information;
(e)Completing certain payment transactions;
(f)Verifying identity;
(g)Completing sensitive account changes; or
(h)Where Travelo Services reasonably believes additional verification is necessary.

26.3 Delivery of OTP Codes

OTP codes may be delivered through:

(a)SMS text message;
(b)Email;
(c)In-app authentication;
(d)Telephone verification where appropriate; or
(e)Other secure authentication methods introduced by Travelo Services.

26.4 User Responsibilities

Users must:

(a)Keep OTP codes confidential;
(b)Never disclose OTP codes to third parties;
(c)Immediately report any unauthorised verification attempts;
(d)Maintain accurate contact information; and
(e)Take reasonable steps to protect their devices from unauthorised access.

Travelo Services will never ask users to disclose OTP codes to customer support representatives.

27. GPS LOCATION DATA

27.1 Collection of Location Information

Travelo Services processes location information where necessary to provide transportation services.

Location information may include:

(a)Pickup locations;
(b)Destination locations;
(c)Driver GPS location;
(d)Passenger location where permission has been granted;
(e)Journey routes;
(f)Navigation information;
(g)Estimated arrival times;
(h)Journey timestamps;
(i)Distance travelled; and
(j)Historical journey locations.

27.2 Purpose of Location Processing

Location information may be processed for the following purposes:

(a)Matching passengers with nearby drivers;
(b)Driver navigation;
(c)Route optimisation;
(d)Estimated arrival calculations;
(e)Journey monitoring;
(f)Fraud prevention;
(g)Safety monitoring;
(h)Customer support;
(i)Lost property investigations;
(j)Dispute resolution;
(k)Service improvements; and
(l)Compliance with legal obligations.

27.3 Location Permissions

Where required by your device or operating system, Travelo Services will request permission before accessing precise location information.

Users may manage location permissions through their device settings.

Disabling location services may reduce or prevent certain Platform functionality.

27.4 Background Location Processing

Where permitted by law and authorised by the user, the driver application may continue processing location information while the application is operating in the background for purposes including:

(a)Navigation;
(b)Active journey management;
(c)Driver availability;
(d)Passenger safety;
(e)Accurate fare calculation;
(f)Emergency response; and
(g)Fraud prevention.

Background location processing will occur only where reasonably necessary for the operation of the Platform.

During active journeys, Travelo Services may enable authorised location sharing between passengers and drivers to facilitate transportation services.

Where this feature is available, passengers may choose to share journey information with trusted contacts.

Information shared may include:

(a)Driver details;
(b)Vehicle information;
(c)Journey route;
(d)Estimated arrival time;
(e)Live journey progress; and
(f)Other information selected by the passenger.

Location sharing with trusted contacts remains optional unless otherwise required by applicable law or emergency circumstances.

28.3 Safety Purposes

Live location sharing may also be used to:

(a)Assist customer support;
(b)Respond to emergency incidents;
(c)Investigate safety concerns;
(d)Locate passengers or drivers during emergencies;
(e)Assist law enforcement where legally required; and
(f)Protect users from fraudulent activity.

29. JOURNEY HISTORY

29.1 Journey Records

Travelo Services maintains records relating to journeys completed, cancelled or otherwise processed through the Platform.

Journey records may include:

(a)Booking reference;
(b)Pickup location;
(c)Destination;
(d)Journey route;
(e)Date and time;
(f)Journey duration;
(g)Distance travelled;
(h)Driver information;
(i)Vehicle information;
(j)Fare information;
(k)Payment method;
(l)Discounts applied;
(m)Waiting time;
(n)Additional stops;
(o)Toll charges;
(p)Parking charges;
(q)Customer support records; and
(r)Ratings associated with the journey.

29.2 Purpose of Journey History

Journey history is maintained for purposes including:

(a)Receipt generation;
(b)Customer support;
(c)Lost property assistance;
(d)Safety investigations;
(e)Fraud prevention;
(f)Regulatory compliance;
(g)Financial reporting;
(h)Service improvements;
(i)Driver payments;
(j)Dispute resolution; and
(k)Compliance with legal obligations.

30. PANIC BUTTON AND EMERGENCY ASSISTANCE

30.1 Purpose of the Panic Button

Where available, Travelo Services provides an emergency assistance feature commonly referred to as the “Panic Button.”

This feature is intended solely for genuine emergencies requiring immediate assistance.

30.2 Information Processed During Emergency Events

Where the Panic Button is activated, Travelo Services may process:

(a)User identity;
(b)Driver identity;
(c)Passenger identity;
(d)Vehicle information;
(e)Live GPS location;
(f)Journey information;
(g)Booking details;
(h)Time of activation;
(i)Emergency contact information where available;
(j)Communications relating to the incident; and
(k)Other information reasonably necessary to respond to the emergency.

Where necessary to protect life, health or public safety, Travelo Services may share relevant information with:

(a)Emergency services;
(b)Police;
(c)Ambulance services;
(d)Fire and rescue services;
(e)Regulatory authorities;
(f)Customer support personnel; and
(g)Other organisations authorised by law.

Only information reasonably necessary to respond to the emergency will be disclosed.

31. RATINGS AND REVIEWS

31.1 Purpose

Passengers and drivers may submit ratings and reviews following completed journeys.

These ratings assist Travelo Services in maintaining service quality and improving user experience.

31.2 Information Processed

Ratings and reviews may include:

(a)Numerical ratings;
(b)Written comments;
(c)Service quality feedback;
(d)Safety feedback;
(e)Cleanliness feedback;
(f)Driver professionalism;
(g)Passenger behaviour reports; and
(h)Other feedback voluntarily provided.

31.3 Use of Ratings

Ratings and reviews may be used to:

(a)Improve service quality;
(b)Investigate complaints;
(c)Identify fraudulent activity;
(d)Reward excellent service;
(e)Identify training opportunities;
(f)Improve platform safety; and
(g)Monitor compliance with Platform standards.

32.1 Promotional Programmes

Travelo Services may operate promotional campaigns, discount programmes and referral schemes.

Participation is voluntary.

32.2 Information Processed

Where users participate, Travelo Services may process:

(a)Referral codes;
(b)Promotional codes;
(c)Account identifiers;
(d)Reward eligibility;
(e)Reward history;
(f)Promotional credits;
(g)Redemption records;
(h)Campaign participation; and
(i)Fraud prevention information.

32.3 Abuse Prevention

Travelo Services reserves the right to investigate promotional activity to detect:

(a)Duplicate accounts;
(b)Fraudulent referrals;
(c)Abuse of promotional offers;
(d)Automated account creation;
(e)Misuse of promotional credits; and
(f)Any activity inconsistent with the applicable promotional terms.

Where abuse is identified, Travelo Services may remove promotional credits, suspend accounts or take other appropriate action.

33. MARKETING COMMUNICATIONS

33.1 Marketing Activities

Travelo Services may communicate with users regarding products, services, promotions and other information that may be of interest.

Marketing communications will only be sent where permitted by applicable law and, where required, with your consent.

33.2 Types of Marketing Communications

Marketing communications may include:

(a)Promotional offers;
(b)Discount campaigns;
(c)Referral programme invitations;
(d)Loyalty rewards;
(e)Seasonal promotions;
(f)Service announcements;
(g)New feature notifications;
(h)Customer surveys;
(i)Newsletters;
(j)Competitions;
(k)Prize draws; and
(l)Other marketing communications relating to Travelo Services.

33.3 Communication Methods

Marketing communications may be delivered through:

(a)Email;
(b)SMS;
(c)Push notifications;
(d)In-app messages;
(e)Telephone where legally permitted; and
(f)Other electronic communication channels authorised by applicable law.

33.4 Marketing Preferences

Users may update their marketing preferences at any time by:

(a)Accessing account settings;
(b)Following unsubscribe instructions;
(c)Contacting customer support; or
(d)Using any other preference management tools made available by Travelo Services.

Certain non-marketing communications relating to bookings, payments, security, legal obligations or account administration cannot be disabled.

Where marketing communications are based upon consent, consent may be withdrawn at any time.

Withdrawal of consent shall not affect the lawfulness of processing undertaken before consent was withdrawn.

34. COOKIES AND SIMILAR TECHNOLOGIES

34.1 What Are Cookies?

Cookies are small text files stored on your device when you visit our website or use certain online services.

Cookies help us improve website functionality, enhance user experience, remember preferences and maintain security.

34.2 Types of Cookies We Use

Travelo Services may use:

(a)Strictly necessary cookies;
(b)Authentication cookies;
(c)Security cookies;
(d)Functional cookies;
(e)Preference cookies;
(f)Performance cookies;
(g)Analytics cookies;
(h)Advertising cookies where permitted;
(i)Session cookies; and
(j)Persistent cookies.

34.3 Necessary Cookies

Necessary cookies are essential for the operation of the Platform.

These cookies enable functions including:

(a)User authentication;
(b)Secure login;
(c)Session management;
(d)Booking functionality;
(e)Payment processing;
(f)Fraud prevention;
(g)Security monitoring; and
(h)Website performance.

Necessary cookies cannot normally be disabled without affecting Platform functionality.

34.4 Analytics Cookies

Analytics cookies help Travelo Services understand how users interact with our website and applications.

Analytics information may include:

(a)Pages visited;
(b)Session duration;
(c)Navigation patterns;
(d)Device information;
(e)Browser information;
(f)General geographic region;
(g)Traffic sources;
(h)Feature usage; and
(i)Performance metrics.

Analytics information is generally used in aggregated form wherever reasonably practicable.

34.5 Functional Cookies

Functional cookies allow the Platform to remember user preferences, including:

(a)Preferred language;
(b)Login preferences;
(c)Accessibility settings;
(d)Interface customisation;
(e)Notification preferences; and
(f)Other user-selected settings.

34.6 Managing Cookies

Most internet browsers allow users to:

(a)View cookies;
(b)Delete cookies;
(c)Block cookies;
(d)Restrict cookies;
(e)Receive notifications before cookies are stored; and
(f)Configure cookie preferences.

Disabling certain cookies may reduce the functionality of the Platform.

35. WEBSITE ANALYTICS

35.1 Purpose of Analytics

Travelo Services analyses website and application usage to:

(a)Improve Platform performance;
(b)Identify technical issues;
(c)Improve user experience;
(d)Measure feature effectiveness;
(e)Develop new functionality;
(f)Improve website navigation;
(g)Detect system errors;
(h)Monitor security; and
(i)Support business decision-making.

35.2 Information Analysed

Analytics may include:

(a)Website traffic;
(b)Application usage;
(c)Feature popularity;
(d)Booking behaviour;
(e)Device information;
(f)Browser information;
(g)Operating system information;
(h)Session duration;
(i)General geographic information;
(j)Referral sources; and
(k)Performance statistics.

Where reasonably practicable, analytics information is aggregated or anonymised.

36. DEVICE INFORMATION

36.1 Device Information Collected

Travelo Services may automatically collect device-related information including:

(a)Device type;
(b)Device manufacturer;
(c)Device model;
(d)Operating system;
(e)Application version;
(f)Browser version;
(g)Screen resolution;
(h)Device identifiers;
(i)Mobile network information;
(j)Language settings;
(k)Time zone;
(l)Internet Protocol (IP) address;
(m)Diagnostic information;
(n)Security information;
(o)Crash reports; and
(p)Device performance information.

36.2 Purpose of Device Information

Device information helps Travelo Services:

(a)Maintain compatibility;
(b)Improve application performance;
(c)Detect security threats;
(d)Investigate technical issues;
(e)Improve customer support;
(f)Prevent fraudulent activity;
(g)Identify software errors;
(h)Enhance cybersecurity; and
(i)Improve overall Platform reliability.

37. CYBERSECURITY MONITORING

37.1 Security Monitoring

Travelo Services continuously monitors its systems to identify, prevent and respond to cybersecurity threats.

Monitoring activities are undertaken to protect users, systems, payment information and business operations.

37.2 Information Processed

Cybersecurity monitoring may involve processing:

(a)Login activity;
(b)Authentication records;
(c)Device identifiers;
(d)IP addresses;
(e)Network activity;
(f)Security event logs;
(g)Failed login attempts;
(h)Suspicious account activity;
(i)Malware detection information;
(j)Application security events;
(k)Firewall logs;
(l)Intrusion detection records;
(m)System alerts; and
(n)Other information necessary to maintain Platform security.

37.3 Automated Security Measures

Travelo Services may automatically:

(a)Detect suspicious activity;
(b)Restrict access;
(c)Suspend compromised accounts;
(d)Block malicious devices;
(e)Prevent fraudulent transactions;
(f)Require additional verification;
(g)Limit access from unusual locations; and
(h)Take other proportionate security measures designed to protect the Platform and its users.

38. PLATFORM SECURITY

38.1 Security Measures

Travelo Services maintains administrative, organisational and technical safeguards designed to protect personal data.

Security measures may include:

(a)Encryption;
(b)Secure communication protocols;
(c)Multi-factor authentication where appropriate;
(d)Role-based access controls;
(e)Secure password storage;
(f)Firewalls;
(g)Malware protection;
(h)Intrusion detection systems;
(i)Security monitoring;
(j)Vulnerability assessments;
(k)Penetration testing where appropriate;
(l)Security audits;
(m)Secure cloud infrastructure;
(n)Data backup procedures;
(o)Disaster recovery planning; and
(p)Employee security training.

38.2 User Responsibilities

Users are responsible for helping maintain the security of their accounts by:

(a)Choosing strong passwords;
(b)Protecting login credentials;
(c)Keeping devices secure;
(d)Installing security updates;
(e)Reporting suspicious activity immediately;
(f)Logging out of shared devices; and
(g)Avoiding disclosure of confidential authentication information.

38.3 No Absolute Security Guarantee

Although Travelo Services implements comprehensive security measures, no method of electronic transmission, internet communication or electronic storage can be guaranteed to be completely secure.

Accordingly, while Travelo Services takes reasonable steps to protect personal data, absolute security cannot be guaranteed.

39.1 General Principles

Travelo Services shares personal data only where such sharing is necessary to provide our Services, comply with legal obligations, protect legitimate interests or where otherwise authorised by applicable law.

We do not sell personal data to third parties.

All disclosures are made in accordance with applicable data protection legislation and are limited to the information reasonably necessary for the relevant purpose.

39.2 Categories of Recipients

Personal data may be shared with:

(a)Drivers;
(b)Passengers;
(c)Fleet Operators;
(d)Corporate Account administrators;
(e)Payment service providers;
(f)Cloud service providers;
(g)Identity verification providers;
(h)Driver licence verification providers;
(i)Customer support providers;
(j)Fraud prevention organisations;
(k)Analytics providers;
(l)Marketing service providers where permitted;
(m)Professional advisers;
(n)Insurance providers;
(o)Regulatory authorities;
(p)Government departments;
(q)Courts and tribunals;
(r)Law enforcement agencies;
(s)Emergency services; and
(t)Other recipients where required or permitted by law.

To facilitate bookings, Travelo Services may share limited information between passengers and drivers, including:

(a)First name;
(b)Pickup location;
(c)Destination;
(d)Booking reference;
(e)Estimated arrival information;
(f)Journey status;
(g)Vehicle details;
(h)Driver profile information;
(i)Passenger instructions relevant to the booking; and
(j)Other information reasonably necessary to complete the journey.

Travelo Services limits the information shared to what is reasonably required for the provision of transportation services.

Where bookings involve Fleet Operators, relevant information may be shared for operational purposes, including:

(a)Driver allocation;
(b)Booking management;
(c)Vehicle assignment;
(d)Payment administration;
(e)Regulatory compliance;
(f)Complaint handling;
(g)Operational reporting; and
(h)Fleet management.

Where bookings are made through a Corporate Account, Travelo Services may share information with authorised corporate administrators, including:

(a)Employee booking information;
(b)Journey dates and times;
(c)Pickup and destination locations;
(d)Fare information;
(e)Booking references;
(f)Departmental cost information;
(g)Expense reporting information; and
(h)Other information necessary to administer the corporate travel programme.

40. SERVICE PROVIDERS

40.1 Third-Party Service Providers

Travelo Services engages carefully selected third-party service providers to assist in operating the Platform.

Service providers process personal data only on our documented instructions unless otherwise required by law.

40.2 Categories of Service Providers

Service providers may include:

(a)Cloud hosting providers;
(b)Payment processors;
(c)Identity verification providers;
(d)Mapping and navigation providers;
(e)Communication providers;
(f)Customer support providers;
(g)Analytics providers;
(h)Security providers;
(i)Fraud prevention providers;
(j)Software development providers;
(k)Infrastructure providers;
(l)Data storage providers;
(m)Disaster recovery providers; and
(n)Professional advisers.

40.3 Data Processing Agreements

Where required by applicable law, Travelo Services enters into appropriate contractual arrangements with service providers to ensure that personal data is processed securely and only for authorised purposes.

Such agreements may include obligations relating to:

(a)Confidentiality;
(b)Security measures;
(c)Data retention;
(d)Sub-processing;
(e)Assistance with data subject rights;
(f)Breach notification; and
(g)Deletion or return of personal data upon termination of services.

41. PAYMENT SERVICE PROVIDERS

41.1 Payment Processing

Payments made through the Platform are processed by authorised third-party payment providers.

These providers process payment information in accordance with their own legal obligations and applicable payment industry standards.

41.2 Information Shared

Information shared with payment providers may include:

(a)Account identifiers;
(b)Transaction amounts;
(c)Payment references;
(d)Payment method information;
(e)Booking references;
(f)Fraud prevention information;
(g)Currency information;
(h)Billing information; and
(i)Other information necessary to complete authorised transactions.

41.3 Payment Security Standards

Payment providers are expected to maintain appropriate technical and organisational security measures, including compliance with applicable industry standards such as the Payment Card Industry Data Security Standard (PCI DSS), where applicable.

42. CLOUD HOSTING AND INFRASTRUCTURE

42.1 Cloud Services

Travelo Services may store and process personal data using secure cloud infrastructure operated by carefully selected service providers.

42.2 Cloud Security

Cloud service providers are required to implement appropriate safeguards designed to protect personal data against:

(a)Unauthorised access;
(b)Accidental loss;
(c)Destruction;
(d)Alteration;
(e)Disclosure;
(f)Cybersecurity threats; and
(g)Other reasonably foreseeable risks.

42.3 Access Controls

Access to cloud-hosted personal data is restricted to authorised personnel who require such access for legitimate business purposes.

Access permissions are regularly reviewed and updated.

43. INTERNATIONAL DATA TRANSFERS

43.1 International Operations

Travelo Services operates internationally and may process personal data in multiple jurisdictions, including the United Kingdom, Malta and Pakistan.

Accordingly, personal data may be transferred to, stored in or accessed from countries outside the United Kingdom or the European Economic Area (“EEA”).

43.2 Transfer Safeguards

Where personal data is transferred internationally, Travelo Services implements appropriate safeguards in accordance with applicable data protection legislation.

Such safeguards may include:

(a)Adequacy regulations or adequacy decisions;
(b)Standard Contractual Clauses (“SCCs”);
(c)International Data Transfer Agreements (“IDTAs”);
(d)Binding contractual obligations;
(e)Technical safeguards, including encryption;
(f)Organisational security measures; and
(g)Other lawful transfer mechanisms recognised under applicable law.

43.3 Risk Assessments

Where required, Travelo Services carries out transfer risk assessments to evaluate whether international transfers provide an appropriate level of protection for personal data.

Where additional safeguards are necessary, supplementary technical, organisational or contractual measures may be implemented.

44. DISCLOSURES REQUIRED BY LAW

44.1 Legal Requirements

Travelo Services may disclose personal data where disclosure is required or authorised by applicable law.

Examples include compliance with:

(a)Court orders;
(b)Search warrants;
(c)Statutory notices;
(d)Regulatory investigations;
(e)Licensing authority requirements;
(f)Tax obligations;
(g)Financial crime investigations;
(h)Anti-money laundering legislation; and
(i)Other legally binding obligations.

44.2 Protection of Rights

Travelo Services may also disclose personal data where reasonably necessary to:

(a)Protect the rights of users;
(b)Protect the rights of Travelo Services;
(c)Prevent fraud;
(d)Investigate criminal activity;
(e)Enforce contractual rights;
(f)Protect public safety;
(g)Defend legal claims; or
(h)Exercise legal rights.

45. EMERGENCY DISCLOSURES

45.1 Protection of Life and Safety

Where Travelo Services reasonably believes that disclosure is necessary to protect life, prevent serious injury or respond to an emergency, relevant personal data may be disclosed to:

(a)Police;
(b)Ambulance services;
(c)Fire and rescue services;
(d)Medical professionals;
(e)Emergency responders;
(f)Government authorities; or
(g)Other organisations authorised to receive such information under applicable law.

45.2 Limited Disclosure

Emergency disclosures will be limited to the information reasonably necessary to address the relevant emergency and protect affected individuals.

46. DATA RETENTION

46.1 General Retention Principles

Travelo Services retains personal data only for as long as is reasonably necessary to fulfil the purposes for which it was collected, including the provision of our Services, compliance with legal obligations, resolution of disputes, enforcement of agreements and protection of our legitimate business interests.

Once personal data is no longer required, it will be securely deleted, anonymised or otherwise disposed of in accordance with applicable law and our internal data retention procedures.

46.2 Factors Used to Determine Retention Periods

When determining appropriate retention periods, Travelo Services considers:

(a)The purpose for which the information was collected;
(b)The nature and sensitivity of the personal data;
(c)Applicable legal and regulatory requirements;
(d)Contractual obligations;
(e)Accounting and taxation requirements;
(f)Limitation periods for legal claims;
(g)Ongoing disputes or investigations;
(h)Fraud prevention requirements;
(i)Information security considerations; and
(j)The legitimate interests of Travelo Services and its users.

46.3 Examples of Retention Periods

Depending upon the nature of the information, Travelo Services may retain data relating to:

(a)User account information;
(b)Booking history;
(c)Driver records;
(d)Fleet operator records;
(e)Corporate account records;
(f)Payment transactions;
(g)Customer support communications;
(h)Complaint investigations;
(i)Fraud investigations;
(j)Safety incidents;
(k)Regulatory compliance records; and
(l)Financial records.

Certain information may be retained for longer periods where required by law or where necessary to establish, exercise or defend legal claims.

46.4 Secure Deletion

When personal data reaches the end of its retention period, Travelo Services will take appropriate measures to ensure secure disposal.

Such measures may include:

(a)Secure electronic deletion;
(b)Cryptographic erasure;
(c)Permanent anonymisation;
(d)Secure destruction of physical records; and
(e)Other industry-recognised disposal methods appropriate to the nature of the information.

47. YOUR DATA PROTECTION RIGHTS

47.1 General Rights

Subject to applicable law, individuals may have the following rights in relation to their personal data:

(a)Right of access;
(b)Right to rectification;
(c)Right to erasure;
(d)Right to restrict processing;
(e)Right to data portability;
(f)Right to object;
(g)Rights relating to automated decision-making;
(h)Right to withdraw consent where processing is based upon consent; and
(i)Right to lodge a complaint with a supervisory authority.

Certain rights may be limited where exemptions or legal restrictions apply.

48. RIGHT OF ACCESS

48.1 Access Requests

You may request confirmation as to whether Travelo Services processes your personal data.

Where applicable, you may also request access to that personal data together with supplementary information required under applicable data protection legislation.

48.2 Information Provided

Where legally required, Travelo Services may provide information including:

(a)Categories of personal data processed;
(b)Purposes of processing;
(c)Categories of recipients;
(d)Retention periods;
(e)Sources of personal data where not obtained directly from you;
(f)Information regarding automated decision-making where applicable; and
(g)Details of your applicable legal rights.

48.3 Verification of Identity

Before responding to an access request, Travelo Services may request reasonable evidence of identity to protect the privacy and security of personal data.

49. RIGHT TO RECTIFICATION

49.1 Correction of Information

You have the right to request correction of inaccurate personal data.

You may also request completion of incomplete personal data where appropriate.

49.2 User Responsibilities

Users should ensure that information maintained within their accounts remains accurate and up to date.

Many account details may be updated directly through the Platform.

50. RIGHT TO ERASURE

50.1 Request for Deletion

Subject to applicable legal requirements, you may request deletion of your personal data where:

(a)The information is no longer necessary;
(b)Consent has been withdrawn;
(c)Processing is unlawful;
(d)You successfully object to processing; or
(e)Applicable law otherwise requires deletion.

50.2 Circumstances Where Deletion May Not Be Possible

Travelo Services may retain certain information where retention is necessary for purposes including:

(a)Compliance with legal obligations;
(b)Tax and accounting requirements;
(c)Fraud prevention;
(d)Public interest;
(e)Regulatory compliance;
(f)Ongoing investigations;
(g)Establishment, exercise or defence of legal claims; and
(h)Other lawful exemptions recognised under applicable legislation.

51. RIGHT TO RESTRICT PROCESSING

51.1 Restriction Requests

You may request restriction of processing in circumstances permitted by applicable law, including where:

(a)Accuracy is contested;
(b)Processing is unlawful but deletion is not requested;
(c)Personal data is required for legal claims; or
(d)An objection to processing is under consideration.

During periods of restriction, personal data may continue to be stored but will generally not be processed except where legally permitted.

52. RIGHT TO DATA PORTABILITY

52.1 Portable Data

Where applicable, you may request a copy of personal data that:

(a)You have provided to Travelo Services;
(b)Is processed by automated means; and
(c)Is processed on the basis of consent or contractual necessity.

52.2 Transfer Requests

Where technically feasible and legally permissible, you may request that such information be transmitted directly to another data controller.

53. RIGHT TO OBJECT

53.1 Objections

You may object to certain processing activities where permitted by applicable law.

Travelo Services will carefully consider each objection and will cease processing where legally required.

53.2 Direct Marketing

You have the right to object at any time to the processing of your personal data for direct marketing purposes.

Where such an objection is received, Travelo Services will cease processing your personal data for direct marketing as soon as reasonably practicable.

54. AUTOMATED DECISION-MAKING

54.1 Automated Processing

Travelo Services may use automated systems to support operational activities including:

(a)Fraud detection;
(b)Booking allocation;
(c)Driver matching;
(d)Risk assessment;
(e)Security monitoring;
(f)Payment verification; and
(g)Service optimisation.

54.2 Human Review

Where decisions producing legal or similarly significant effects are made solely through automated processing and applicable law provides such rights, individuals may request human intervention, express their point of view and contest the decision.

55.1 Withdrawal

Where processing is based upon consent, you may withdraw that consent at any time.

Withdrawal of consent shall not affect the lawfulness of processing carried out before consent was withdrawn.

55.2 Effect of Withdrawal

Withdrawal of consent may affect the availability of certain features or services where processing is necessary for those functions.

56. CHILDREN’S PRIVACY

56.1 Age Restrictions

Travelo Services is intended for individuals who are legally permitted to use private hire transportation services under applicable law.

We do not knowingly collect personal data from children without appropriate legal authority or parental consent where required.

56.2 Discovery of Children’s Information

If Travelo Services becomes aware that personal data has been collected from a child in circumstances contrary to applicable law, reasonable steps will be taken to delete that information or otherwise comply with legal obligations.

57. COMPLAINTS

57.1 Contacting Travelo Services

If you have concerns regarding the processing of your personal data, you are encouraged to contact Travelo Services first so that we may investigate and attempt to resolve the matter promptly.

57.2 Regulatory Complaints

You also have the right to lodge a complaint with the competent data protection supervisory authority in the jurisdiction where you reside, work or where the alleged infringement occurred, in accordance with applicable law.

Travelo Services will cooperate fully with competent supervisory authorities in relation to any lawful investigation or enquiry.

58. PERSONAL DATA BREACH MANAGEMENT

58.1 Commitment to Data Security

Travelo Services is committed to protecting personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure or unauthorised access.

Despite implementing appropriate technical and organisational safeguards, no security system can eliminate every risk. Accordingly, Travelo Services maintains procedures to identify, investigate, contain and respond to actual or suspected personal data breaches.

58.2 What Constitutes a Personal Data Breach

A personal data breach may include, but is not limited to:

(a)Unauthorised access to personal data;
(b)Accidental disclosure of personal information;
(c)Loss or theft of devices containing personal data;
(d)Destruction or corruption of personal data;
(e)Ransomware or malware attacks;
(f)Unauthorised modification of personal data;
(g)Accidental transmission of personal information to an incorrect recipient;
(h)System intrusion;
(i)Insider misuse of information; or
(j)Any other security incident affecting the confidentiality, integrity or availability of personal data.

58.3 Incident Response

Where a personal data breach is suspected or identified, Travelo Services may take appropriate actions including:

(a)Investigating the incident;
(b)Containing the breach;
(c)Securing affected systems;
(d)Preserving relevant evidence;
(e)Assessing risks to affected individuals;
(f)Restoring services where appropriate;
(g)Implementing corrective measures;
(h)Reviewing internal procedures; and
(i)Taking any additional action reasonably necessary to minimise harm.

58.4 Notification of Data Breaches

Where required by applicable law, Travelo Services will notify the relevant supervisory authority and, where legally required, affected individuals without undue delay.

Such notifications may include:

(a)The nature of the breach;
(b)Categories of information affected;
(c)Likely consequences;
(d)Measures taken to address the breach;
(e)Recommended protective actions for affected individuals; and
(f)Contact information for further assistance.

59. SECURITY INCIDENT RESPONSE

59.1 Monitoring

Travelo Services continuously monitors its systems for indicators of potential security incidents.

Monitoring may include:

(a)Login activity;
(b)Authentication events;
(c)Network traffic;
(d)Application activity;
(e)Payment activity;
(f)Device information;
(g)Security alerts;
(h)Intrusion detection systems; and
(i)Other cybersecurity monitoring tools.

59.2 Investigation

Where suspicious activity is detected, Travelo Services may investigate by reviewing:

(a)System logs;
(b)User account activity;
(c)Device identifiers;
(d)Booking records;
(e)Payment records;
(f)Communication records;
(g)GPS information;
(h)Authentication events; and
(i)Other relevant operational information.

59.3 Protective Measures

Where reasonably necessary, Travelo Services may:

(a)Suspend accounts;
(b)Reset passwords;
(c)Require additional identity verification;
(d)Restrict access;
(e)Disable affected services;
(f)Reverse fraudulent activity where possible;
(g)Notify affected users; and
(h)Cooperate with law enforcement or regulatory authorities where appropriate.

60. ACCOUNT SUSPENSION AND RESTRICTION

60.1 Suspension of Accounts

Travelo Services may suspend or restrict user accounts where reasonably necessary to:

(a)Protect Platform security;
(b)Investigate fraud;
(c)Investigate criminal activity;
(d)Protect passengers or drivers;
(e)Enforce these policies;
(f)Verify identity;
(g)Investigate payment irregularities;
(h)Comply with legal obligations; or
(i)Protect the rights of Travelo Services or other users.

60.2 Temporary Restrictions

During an investigation, Travelo Services may temporarily restrict certain account features, including:

(a)Booking services;
(b)Driver access;
(c)Wallet withdrawals;
(d)Promotional benefits;
(e)Payment functionality;
(f)Messaging features; and
(g)Other services reasonably necessary to protect the Platform.

61. ACCOUNT CLOSURE

61.1 User-Initiated Closure

Users may request closure of their accounts by contacting Travelo Services or, where available, using the account settings within the Platform.

Account closure requests remain subject to applicable legal, regulatory and contractual obligations.

61.2 Closure by Travelo Services

Travelo Services may close an account where:

(a)The user requests closure;
(b)Continued use would breach applicable law;
(c)Fraud has been identified;
(d)False information has been provided;
(e)Licensing requirements are no longer satisfied;
(f)Payment abuse has occurred;
(g)Serious misconduct has been identified;
(h)The Platform is being misused; or
(i)Closure is otherwise permitted under our Terms and Conditions.

61.3 Effect of Account Closure

Closure of an account does not automatically require immediate deletion of all associated personal data.

Certain information may continue to be retained where necessary to:

(a)Comply with legal obligations;
(b)Resolve disputes;
(c)Complete financial reconciliation;
(d)Prevent fraud;
(e)Protect legal rights;
(f)Maintain regulatory records; and
(g)Exercise or defend legal claims.

62. DELETION OF PERSONAL DATA

62.1 Deletion Requests

Where users request deletion of personal data, Travelo Services will assess the request in accordance with applicable law.

Deletion may be carried out where:

(a)No overriding legal basis exists for continued retention;
(b)The request is legally valid;
(c)Applicable retention obligations have expired; and
(d)No exemption applies.

62.2 Information That May Be Retained

Travelo Services may continue retaining certain information where necessary for:

(a)Financial record keeping;
(b)Tax compliance;
(c)Fraud prevention;
(d)Safety investigations;
(e)Regulatory compliance;
(f)Insurance claims;
(g)Legal proceedings;
(h)Contract enforcement; and
(i)Other lawful purposes.

63. BUSINESS TRANSFERS

63.1 Corporate Transactions

If Travelo Services undergoes:

(a)A merger;
(b)An acquisition;
(c)A restructuring;
(d)A corporate reorganisation;
(e)Sale of assets;
(f)Investment transaction;
(g)Insolvency process; or
(h)Similar corporate event, personal data may be transferred as part of that transaction, subject to applicable legal requirements.

63.2 Protection During Transfers

Where personal data forms part of a corporate transaction, Travelo Services will take reasonable steps to ensure that the receiving organisation continues to protect personal data in accordance with applicable law.

64. THIRD-PARTY WEBSITES AND SERVICES

64.1 External Links

The Platform may contain links to third-party websites, applications or services that are not operated or controlled by Travelo Services.

64.2 Independent Privacy Practices

Travelo Services is not responsible for the privacy practices, security measures or content of third-party websites or services.

Users should review the privacy policies of any third-party services before providing personal information.

64.3 Third-Party Integrations

Where users choose to interact with third-party services through the Platform, personal data may be processed in accordance with the privacy policies of those third parties.

Travelo Services encourages users to familiarise themselves with those policies before using such integrations.

65. CHANGES TO THIS PRIVACY POLICY

65.1 Updates

Travelo Services may amend this Privacy Policy from time to time to reflect:

(a)Changes in applicable law;
(b)Regulatory guidance;
(c)New services or features;
(d)Changes to our business operations;
(e)Improvements in security;
(f)Technological developments;
(g)Operational requirements; or
(h)Other legitimate business reasons.

65.2 Notification of Changes

Where required by applicable law or where changes are material, Travelo Services will provide appropriate notice before the revised Privacy Policy takes effect.

Notice may be provided through:

(a)The website;
(b)Mobile applications;
(c)Email;
(d)Push notifications;
(e)Account notifications; or
(f)Other appropriate communication methods.

Continued use of the Platform after the effective date of the revised Privacy Policy constitutes acknowledgement of the updated Policy, except where applicable law requires additional consent.

66. GOVERNING LAW

66.1 Applicable Law

This Privacy Policy shall be governed by and interpreted in accordance with the laws applicable to the jurisdiction in which the relevant Travelo Services entity provides the Services.

Where processing activities fall within the scope of:

(a)the United Kingdom General Data Protection Regulation (“UK GDPR”);
(b)the Data Protection Act 2018;
(c)the European Union General Data Protection Regulation (“EU GDPR”);
(d)the laws of Malta; or
(e)applicable data protection legislation in Pakistan,

Travelo Services will process personal data in accordance with those legal requirements.

66.2 Cross-Border Operations

Because Travelo Services operates internationally, different legal requirements may apply depending upon:

(a)Your country of residence;
(b)The country in which Services are provided;
(c)The location of data processing activities;
(d)The location of payment processing; and
(e)Applicable regulatory requirements.

Nothing in this Privacy Policy limits any mandatory legal rights that users are entitled to under applicable law.

67. REGULATORY AUTHORITIES

67.1 Right to Contact a Supervisory Authority

If you believe that Travelo Services has not processed your personal data in accordance with applicable law, you have the right to contact the appropriate supervisory or regulatory authority.

67.2 United Kingdom

For processing activities subject to UK data protection law, complaints may be made to the Information Commissioner’s Office (ICO).

67.3 Malta

For processing activities subject to Maltese or EU data protection law, complaints may be made to the Office of the Information and Data Protection Commissioner (IDPC Malta) or another competent supervisory authority within the European Economic Area.

67.4 Pakistan

Where applicable, individuals may contact the competent governmental or regulatory authority responsible for personal data protection in Pakistan once such authority has jurisdiction over the relevant processing activities.

68. CONTACT DETAILS

68.1 Data Protection Enquiries

Questions regarding this Privacy Policy or the processing of personal data should be directed to:

Travelo Services

Location:

Wirral, United Kingdom

Website:

https://traveloservices.com

Email:

support@traveloservices.com

68.2 Privacy Requests

Requests concerning:

(a)Subject Access Requests;
(b)Rectification;
(c)Erasure;
(d)Restriction of processing;
(e)Data portability;
(f)Objections;
(g)Withdrawal of consent;
(h)Complaints; or
(i)General privacy enquiries, should be submitted using the above contact details.

Travelo Services may request reasonable evidence of identity before responding.

69. SEVERABILITY

If any provision of this Privacy Policy is found by a court or other competent authority to be unlawful, invalid or unenforceable, the remaining provisions shall continue in full force and effect.

Where possible, any invalid provision shall be interpreted so as to give effect to its original commercial and legal purpose to the maximum extent permitted by law.

70. NO WAIVER

Failure by Travelo Services to enforce any provision of this Privacy Policy shall not constitute a waiver of any right or remedy.

Any waiver shall be effective only if made expressly in writing.

71. ENTIRE PRIVACY POLICY

This Privacy Policy constitutes the entire privacy notice of Travelo Services relating to the collection, use, disclosure, retention and protection of personal data through our website, mobile applications and related Services.

Where additional notices are provided for specific services or jurisdictions, those notices shall supplement this Privacy Policy.

72. LANGUAGE

This Privacy Policy has been prepared in the English language.

Where translations are provided, the English version shall prevail to the extent permitted by applicable law in the event of any inconsistency.

73. VERSION CONTROL

Version	Effective date	Description
1.0	to be confirmed	Initial publication of the Travelo Services Privacy Policy

APPENDIX A — CATEGORIES OF PERSONAL DATA

Travelo Services may process the following categories of personal data:

Identity Information
Contact Information
Account Information
Driver Licensing Information
Vehicle Information
Fleet Information
Corporate Account Information
Booking Information
Journey History
GPS and Location Data
Payment Information
Wallet Information
Driver Earnings
Ratings and Reviews
Customer Support Records
Communications
Device Information
Technical Information
Usage Analytics
Marketing Preferences
Cookie Data
Security Logs
Fraud Prevention Information
Identity Verification Records
Emergency Assistance Records
Regulatory Compliance Information

APPENDIX B — CATEGORIES OF RECIPIENTS

Personal data may be shared, where appropriate, with:

Drivers
Passengers
Fleet Operators
Corporate Account Administrators
Payment Providers
Banking Partners
Identity Verification Providers
Mapping and Navigation Providers
Communication Service Providers
Cloud Hosting Providers
Customer Support Providers
Fraud Prevention Agencies
Professional Advisers
Insurance Providers
Regulatory Authorities
Government Agencies
Emergency Services
Courts and Tribunals
Law Enforcement Authorities
Auditors
Technology Service Providers

APPENDIX C — LEGAL BASES MATRIX

Travelo Services processes personal data using one or more of the following lawful bases where applicable:

Performance of a Contract
Compliance with a Legal Obligation
Legitimate Interests
Consent
Protection of Vital Interests
Performance of a Task Carried Out in the Public Interest
Other lawful bases recognised under applicable legislation

APPENDIX D — DATA RETENTION SCHEDULE

Retention periods are determined according to:

Legal requirements
Regulatory obligations
Accounting obligations
Tax legislation
Fraud prevention
Safety investigations
Contractual obligations
Limitation periods
Business continuity requirements
Legitimate business interests

Where personal data is no longer required, it will be securely deleted, anonymised or destroyed.

The Platform may use:

Essential Cookies
Authentication Cookies
Security Cookies
Functional Cookies
Preference Cookies
Performance Cookies
Analytics Cookies
Advertising Cookies (where applicable)
Session Cookies
Persistent Cookies

Users may manage cookie preferences through browser settings or any cookie preference tools made available by Travelo Services.

APPENDIX F — SECURITY MEASURES

Travelo Services maintains a comprehensive information security programme, which may include:

Encryption of data in transit and, where appropriate, at rest.
Role-based access controls and least-privilege access.
Multi-factor authentication for administrative access where appropriate.
Secure software development practices.
Firewall protection and intrusion detection/prevention systems.
Continuous security monitoring and logging.
Vulnerability scanning and penetration testing where appropriate.
Secure backup and disaster recovery procedures.
Staff training on information security and data protection.
Incident response and breach management procedures.
measures.

Regular review and enhancement of technical and organisational security

FINAL STATEMENT

Travelo Services is committed to protecting the privacy, confidentiality and security of the personal data entrusted to us. We continually review and improve our privacy practices to ensure compliance with applicable laws, industry standards and evolving best practices while delivering safe, reliable and innovative transportation services.

—1. INTRODUCTION

1.1 Purpose of this Privacy Policy

1.2 Our Commitment to Privacy

1.3 Who This Privacy Policy Applies To

1.4 About Our Services

1.5 Applicable Privacy Laws

—2. DEFINITIONS

2.1 “Account”

2.2 “Applicable Law”

2.3 “Booking”

2.4 “Controller”

2.5 “Corporate Account”

2.6 “Customer”

2.7 “Data Processor”

2.8 “Driver”

2.9 “Fleet Operator”

2.10 “Personal Data”

2.11 “Platform”

2.12 “Processing”

2.13 “Sensitive Personal Data”

2.14 “Services”

2.15 “User”

—3. SCOPE OF THIS PRIVACY POLICY

3.1 General Scope

3.2 Activities Covered

3.3 Territorial Scope

3.4 Third-Party Services

3.5 Services Outside Our Control

—4. ABOUT TRAVELO SERVICES

4.1 Company Information

4.2 Company Details

4.3 Our Role

—5. DATA CONTROLLER

5.1 Identity of the Data Controller

5.2 Responsibilities of the Data Controller

—6. CONTACT DETAILS FOR PRIVACY ENQUIRIES

—7. DATA PROTECTION PRINCIPLES

7.1 Lawfulness, Fairness and Transparency

7.2 Purpose Limitation

7.3 Data Minimisation

7.4 Accuracy

7.5 Storage Limitation

7.6 Integrity and Confidentiality

7.7 Accountability

—8. INTERPRETATION

8.1 Headings

8.2 Singular and Plural

8.3 Gender

8.4 References to Legislation

8.5 Severability

—9. GENERAL PROVISIONS

9.1 Good Faith

9.2 Privacy by Design

9.3 Privacy by Default

9.4 Continuous Improvement

—10. CATEGORIES OF PERSONAL DATA WE COLLECT

10.1 Identity Information

10.2 Contact Information

10.3 Account Information

10.4 Booking Information

10.5 Payment Information

10.6 Location Information

10.7 Device Information

10.8 Communication Information

10.9 Driver Information

10.10 Vehicle Information

10.11 Corporate Account Information

10.12 Fleet Operator Information

10.13 Verification Information

10.14 Safety Information

10.15 Marketing Information

10.16 Technical Information

10.17 Usage Information

10.18 Cookies and Online Identifiers

10.19 Information Received from Third Parties

10.20 Information You Choose to Provide

—11. HOW WE COLLECT PERSONAL DATA

11.1 Information You Provide Directly

11.2 Information Collected Automatically

11.3 Information Collected from Third Parties

1. INTRODUCTION

2. DEFINITIONS

3. SCOPE OF THIS PRIVACY POLICY

4. ABOUT TRAVELO SERVICES

5. DATA CONTROLLER

6. CONTACT DETAILS FOR PRIVACY ENQUIRIES

7. DATA PROTECTION PRINCIPLES

8. INTERPRETATION

9. GENERAL PROVISIONS

10. CATEGORIES OF PERSONAL DATA WE COLLECT

11. HOW WE COLLECT PERSONAL DATA

12. LAWFUL BASES FOR PROCESSING PERSONAL DATA

13. PASSENGER DATA PROCESSING

14. DRIVER DATA PROCESSING

15. FLEET OPERATOR DATA PROCESSING

16. CORPORATE ACCOUNT DATA PROCESSING

17. IDENTITY VERIFICATION

18. DRIVER LICENCE AND VEHICLE VERIFICATION

19. PAYMENT INFORMATION PROCESSING

20. STRIPE CARD PRE-AUTHORISATION

21. APPLE PAY AND GOOGLE PAY

22. DIGITAL WALLET

23. DRIVER WALLET

24. DRIVER PAYOUTS