Who we are
Carfly (“We”) is committed to protecting and respecting your privacy, and safeguarding your data and individual-level information in a secure, respectful and trustworthy manner.
This notice sets out how we will process any personal data we collect from you, or that you provide to us. Please read the following carefully to understand our views, practices and processes regarding your personal data and how we will treat this information.
For the purposes of the Data Protection Act 2018 and the General Data Protection Regulation, referred to collectively as ‘the Legislation’, the data controller is Carfly, Landmark West Tower, 22 Marsh Wall, London E14 9AL.
Carfly is committed to, and fully compliant with all our statutory and legislative regulations to ensure the security and confidentiality of the data relating to that of our customers, our staff and all associated third parties. Our computer-based processes and systems, adhere to the standards set by the Legislation.
We ensure that our company servers, personal computers (PCs), laptops and company mobile devices are suitably secure for the purposes of our work with our customers and suppliers.
The information we collect
We will use your personal and non-personal information only for the purposes for which it was collected or agreed with you, for example:
- To carry out our obligations arising from any agreement entered into between you and us;
- To notify you about changes to our service;
- For the detection and prevention of fraud, crime, or other malpractice;
- To conduct market or customer satisfaction research or for statistical analysis;
- For audit and record keeping purposes;
- In connection with legal proceedings;
- To respond to your queries or comments.
- Data gathered from other sources – like state authorities.
Data provided by users
- User profile data, such as: first name, last name, email, mobile number, physical address, payment and bank account data, driving license data, user vehicle data, user photos. User photo needs to be provided in order to meet requirements of “Name of the Legislative Act” (or some other similar text);
- User profile data, such as: first name, last name, email, mobile number, physical address, payment and bank account data, driving license data, user vehicle data, user photos. It is required by the law to provide driver photo;
- Checking documents and verifying driver’s identity might require checking licenses, photos, user name and last name;
- Some data can be provided when users turn to technical support, trip data (date and time, physical addresses, flight information).
We collect and process your personal information mainly to provide you with access to our services and products, to help us improve our offerings to you and for certain other purposes explained below. We do not knowingly set out to collect personal data, it is only provided to us by you by contacting us via our website www.carfly.co (“our website”) by phone or by email. Once collected, this data is only used to deliver the service and to respond to you, answer any questions you have. We do not collect sensitive data – financial, health or information about children. This does however include name, phone number, email etc. We collect and process the following information relating to our customers:
- Information collected includes information provided at the time of making bookings for our services or for any other reason if you need to make a complaint or report a problem with our site. Examples of information we collect from you are names, email address and telephone number and this is done at the point of creating an account with Carfly;
- If you contact us, we may keep a record of that correspondence. If you contact us by telephone, your telephone call may be recorded for monitoring and quality purposes;
- We may also ask you to complete surveys that we use for research purposes, although you do not have to respond to them;
- To confirm and verify your identity or to verify that you are an authorised customer for security and compliance purposes;
Employees and Drivers
We will collect information relevant to our legal obligations as an employer or as a contracted party for drivers and may include your name, phone number and email, in addition to address, licencing information and information relating to criminal convictions, health information and other information as part of our screening and vetting processes.
Why we need it
We need to know your personal data in order to reply to you and provide you with services. We will not collect any personal data from you which we do not need to provide and oversee this service to you. The lawful basis for processing data identified by Carfly includes:
- Legal obligations (for example, as an employer or as part of obligations with regards to HMRC);
- Performance of a contract (especially with regards to our customers and our suppliers);
- Legitimate interest (such as when we ask for your feedback or advice on how to continually improve);
- Consent (only used when sensitive information is required to be processed by us).
What we do with it
The personal data we process is processed and hosted in the UK. Third parties will have access to your personal data only when they are under contract and following the signature of a non-disclosure agreement and only in line with the services these third parties are contracted to do so in order for Carfly to function as a business.
What we may do with the personal data
Customers (website and phone users)
- Data will be disclosed to the designated driver on a fare by fare basis so as they can complete the service requested;
- Auditors, consultants and specialist service providers for the purposes of ensuring Carfly operate legally and safely. These include hosting and IT services providers, critical to the infrastructure of our website;
- Transport for London (upon receipt of a proper and justified request);
- Police and other regulatory authorities (upon receipt of a proper and justified request).
- Service providing
- Security providing
- Customer support
- Research and development
- Sending non-marketing messages
- Sending marketing messages, with option to optout
- Fulfilling legislation requirements and court orders
- Business process automation.
1. Service Providing
Carfly uses data for proving, personification, support and improving of its services. Such as:
- Creating accounts and changing its data;
- Providing riding service, data exchange (security providing, routes calculation, linking to flight information, tracking and sending information about a ride);
- Payment processing and other financial data;
- Performing operations which are needed in order to improve service and customer support, testing, analysis and also monitoring of services used;
2. Security Providing
Carfly uses data for proving security and protection of users and also security for our services. This includes:
- In order to comply with government requirements we may ask to provide driver photo and also passing it to passengers;
- Sending information about serious violations to third parties such as police authorities – in accordance to legislation requirements.
3. Client Support
Carfly uses personal data in order to provide technical support and improve quality of its services.
4. Research and Development
Carfly uses personal data in order to perform testing, research, analysis, development and improvement of its services. This helps us to make our services better and more secure and develop new functionality.
5. Sending Non-Marketing Messages
We can use personal data in order to inform our users about changing of terms and rules, and also for sending non-marketing messages which are needed to provide services.
6. Fulfilling Legislation Requirements and Court orders
We can use personal data in order to settle litigations and court orders associated with using of Carfly services, fulfilling law orders, in cases when data is required by public authorities, including police.
Using Cookies
Carfly uses Cookie files in order to: Perform user authentication;
- Save user settings;
- Keep history of rides and other historical user data;
Cookie is a small piece of data which is sent by a web-service and stored on a user device (i.e. personal computer, mobile phone, tablet).
Transfer and Disclosure of User Data
Carfly performs data transfer to other users or provides data on demand in cases where it falls under law requirements or when it is required in order to satisfy claims or settle dispute resolutions. Carfly can transfer user data in the following cases:
1. To Other Users:
- In order to perform a ride we may give to a driver your name, email, telephone, information about pickup location and destination location;
- In order to perform a ride we may give to a passenger driver’s name, photograph, license number, vehicle brand and model and vehicle registration number.
2. Providing Data Under Legislation Grounds or in Dispute Cases.
Carfly may disclose personal data in cases when legislation requires to do so, in court disputes, or when public authorities, including police, require this.
Employees
- Data will be disclosed to drivers so as they can be assisted in the completion of the service purchased by the customer;
- Auditors, consultants and specialist service providers for the purposes of ensuring Carfly operate legally and safely. These include hosting and IT services providers, critical to the infrastructure of our website and app;
- Transport for London
- Police and other regulatory authorities (upon receipt of a proper and justified request).
If there is a duty to disclose or share your personal data in order to comply with any legal obligation, or to enforce or apply our terms and conditions of supply and/or any other agreements; or to protect the rights, property, or safety of Carfly, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
How long we keep it
Under Private Hire Regulations stipulated by Transport for London, we are obliged to retain journey records for a period of 12 months as a condition of our contract. Similarly we are required to keep any complaint, lost property and account query records for the same period of time.
Of course we will look to retain records for no longer than is necessary.
Carfly stores personal data up to the point where goals of its processing which are described in this Agreement are met.
COMPLAINTS
Carfly tries to meet the highest standards when processing and collecting your personal information. In the event that you wish to make a complaint about how we process your personal data, please contact us at info@carfly.co and we will endeavour to deal with your request as soon as possible.
If you are not satisfied with the response from Carfly or believe we are not processing your data in accordance with the law, you have the right to raise your complaint with the Information Commissioner’s Office (ICO).