Privacy Policy

In this policy the following defined terms shall apply:
App: the mobile application (known as WYSTLE) through which the Services may be accessed.
Cookie Policy: the cookie policy (as amended by Us from time to time) as set out.
Customer: an individual authorised to use the Platforms (having accepted the Customer T&Cs) for the purposes of requesting Transport Services and entering into Transport Contracts.
Customer T&CS: the terms and conditions (as amended by Us from time to time) as set out.
Device: any computer, telephone or other similar device through which either Platform is accessed.
Platforms: the App and/or the Website.
Terms Pack: the Vehicle Operator T&Cs, this Policy, the Cookie Policy and all documents referred to therein (as amended from time to time by Us).
Transport Contract: a contract (obtained through the use of the Platforms) entered into between a Customer and a Transport Supplier for the provision of Transport Services.
Transport Services: transportation from and to specified locations.
Transport Supplier: the business or company (i) which employs you (ii) to whom you report (iii) from which you obtain your instructions; (iv) who acts as a booking agent on your behalf; or (iv) who otherwise engages you to provide Transport Services (but for the avoidance of doubt, excluding Us).
Us/We/Our: MINICABBID SVHI LIMITED a private limited company registered in England with company number 09724565 whose registered office is at 3 Coombe Road, London, England, NW10 0EB.
Vehicle: the vehicle used by you to provide the Transport Services.
Vehicle Operator T&CS: the terms and conditions (as amended by Us from time to time) as set out.
Website: the web based application (known as WYSTLE) through which the Services may be accessed.

SCOPE OF POLICY
This policy applies to your use of the Platforms and any services accessible through the Platforms (“Services”), unless the Vehicle Operator T&Cs state that a separate privacy policy applies to a particular Service, in which case that privacy policy only applies. This policy sets out the basis on which any personal data We collect from you, or that you provide to Us, will be processed by Us. Please read the following carefully to understand Our views and practices regarding your personal data and how We will treat it. For the purpose of the Data Protection Act 1998, the data controller is MINICABBID SVHI LIMITED (Company Number: 09724565) of 3 Coombe Road, London, England, NW10 0EB

INFORMATION WE COLLECT FROM YOU
We will collect and process the following data about you:
• Information you give Us (“Submitted information”): This is information you give Us about you by filling in forms on the Platforms, or by corresponding with Us (for example, in writing, by e-mail or chat). It includes information you provide when you:

- download the App;
- register a user account on either of the Platforms;
- subscribe to, request and/or use any of the Services;
- register a bank account through which payments may be made or taken in relation to any Transport Services you provide;
- share data via either Platforms social media functions; and
- report a problem or complaint; with either of the Platforms; with the Services; or arising out of the provision of any Transport Services.

The information you give Us may include: your name; residential address; e-mail address; date of birth; phone number; username; password and other registration information; financial, bank and credit card information; personal description and photograph; Vehicle registration; driving licence; other Vehicle documentation; and local authority licencing documentation.
• Information We collect about you and your Device. Each time you use either of the Platforms We will automatically collect the following information:

• technical information, including the type of Device you use, a unique device identifier (for example, your Device's IMEI number, the MAC address of the Device's wireless network interface, or the mobile phone number used by the Device), mobile network information, your mobile operating system, the type of mobile browser you use and time zone setting (“Device Information”);
• details of your use of the Platforms including, but not limited to traffic data, weblogs and other communication data, whether this is required for Our own billing purposes or otherwise and the resources that you access (“Log Information”).

• (“Location information”). We also use GPS technology to determine the location of you and your Device at all times whilst you are logged into any user account that you have created with Us. You can withdraw your consent at any time to Our tracking of your location and Device but some of Our services may no longer be available to you if you do so.
• Information we receive from other sources (“Third Party Information”). We are working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies). We will notify you when We receive information about you from them and the purposes for which We intend to use that information.

COOKIES
We use cookies to distinguish you from other users of the Platforms. This helps Us to provide you with a good experience when you use the Platforms and also allows Us to improve the Platforms. For detailed information on the cookies We use and the purposes for which We use them, see our cookie policy.
USES MADE OF THE INFORMATION
We use information held about you in the following ways:
• Submitted Information:
- to ensure that content is presented in the most effective manner for you and your Device;
- to provide you with information, products or services (content and advertising tailored to your interests);
- to provide you with the Services;
- to maintain, protect and improve the Platforms and Services;
- to notify you about changes to the Platforms, the Terms Pack and any Services;
- to monitor and assist the Transport Supplier to enter into Transport Contracts and to assist you in providing the Transport Services on the Transport Suppliers behalf;
- to assist the Transport Supplier to monitor your use of the Services and performance of Transport Services (relating to Transport Contracts) on their behalf; and
- to make payment to you (where directed by the Transport Supplier) in relation to Transport Services you have provided on their behalf.
• Device information:
- to ensure that content is presented in the most effective manner for you and your Device;
- to provide you with the Services; and
- to maintain, protect and improve Platforms and Services.
• Log information:
- to maintain, protect and improve Platforms and Services;
- to provide you with the Services;
- to monitor and assist the Transport Supplier to enter into Transport Contracts and to assist you in providing the Transport Services on the Transport Suppliers behalf; and
- to assist the Transport Supplier to monitor your use of the Services and performance of Transport Services (relating to Transport Contracts) on their behalf.
• Location information:
- to provide you with the Services;
- to monitor and assist you and the Transport Supplier to provide the Transport Services;
- to monitor and assist the Transport Supplier to enter into Transport Contracts and to assist you in providing the Transport Services on the Transport Suppliers behalf; and
- to assist the Transport Supplier to monitor your use of the Services and performance of Transport Services (relating to Transport Contracts) on their behalf.
• Third Party Information:
- to ensure that content is presented in the most effective manner for you and your Device;
- to provide you with information, products or services (content and advertising tailored to your interests);
- to provide you with the Services;
- to maintain, protect and improve the Platforms and Services; and
- to make payment to you (where directed by the Transport Supplier) in relation to Transport Services you have provided.

DISCLOSURE OF YOUR INFORMATION
We will disclose the data We collect from you to the following third parties:

Category of data	Recipient	Purpose
Submitted Information, Device Information, Location Information, Log Information and Third Party Information.	Transport Supplier.	- to assist the Transport Supplier in entering into Transport Contracts and supplying Transport Services; - to assist the Transport Supplier in monitoring your use of the Services and performance of the Transport Services provided in relation to Transport Contracts; - to assist the Transport Supplier in resolving any complaints, claims for lost property and/or accidents arising in relation to the Transport Services provided under Transport Contracts; and - to assist the Transport Supplier to assess if the correct payments have been made by Customers in relation to the Transport Services provided under Transport Contracts and what payments may or may not be due to you.
Submitted Information and Location Information.	Customers	- to assist the Transport Supplier to enter into Transport Contracts and in providing Transport Services; - to assist Customers in their decision as to whether to enter into a Transport Contract; - to assist Customers in receipt of Transport Services and in complying with any Transport Contracts entered into; and - to assist Customers in relation to complaints, loss of property or accident they suffer whilst receiving Transport Services from you.
Submitted Information and Third Party Information.	Elavon Financial Services DAC a company registered in Ireland.	Elavon are a payment processing agent who assist Us with the processing of: (i) payments made to Us (as payment collection agent for the Transport Supplier); and (ii) (where instructed by a Transport Supplier) payments to you on behalf of the Transport Supplier.
Device Information and Log Information.	Our third party: - website and app developers; and - website and app analysts.	To assist Us in improving the content on and functionality of the Platforms.
Submitted Information, Device Information, Log Information, Location Information and Third Party Information.	Insurers	To assist Customers, the Transport Supplier, you and/or any applicable insurers in investigating and settling any claims made against you or a Transport Supplier or by you or a Transport Supplier.
Submitted Information, Device Information, Log Information, Location Information and Third Party Information	Police and Local Authorities	To assist such parties in any investigations or requests that they may have regarding you and/or any Transport Supplier.

You agree that We have the right to disclose your personal information to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the Companies Act 2006.
We will disclose your personal information to third parties:
• In the event that We sell or buy any business or assets, in which case We will disclose your personal data to the prospective seller or buyer of such business or assets.
• If MINICABBID SVHI LIMITED or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
• If We are under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation or request.
• In order to:
   • to obtain assistance with the processing of any payments to you on behalf of the Transport Supplier;
   • enforce or apply the Terms Pack and other agreements or to investigate potential breaches; and
   • protect the rights, property or safety of MINICABBID SVHI LIMITED, our customers, a Driver, Transport Supplier or others. This includes exchanging information with other companies    and organisations for the purposes of fraud protection and credit risk reduction.

WHERE WE STORE YOUR PERSONAL DATA
Any payment transactions carried out by Us or our chosen third-party provider of payment processing services will be encrypted using Point to Point Encryption. Where we have given you (or where you have chosen) a password that enables you to access the Platforms, you are responsible for keeping this password confidential. We ask you not to share a password with anyone. Unfortunately, the transmission of information via the internet is not completely secure. Although We will do our best to protect your personal data, We cannot guarantee the security of your data transmitted to any of the Platforms; any transmission is at your own risk. Once We have received your information, We will use strict procedures and security features to try to prevent unauthorised access.

YOUR RIGHTS
You have the right to ask Us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if We intend to use your data for such purposes or if We intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms We use to collect your data. You can also exercise the right at any time by contacting us at support@wystle.co.uk.
The Platforms may, from time to time, contain links to and from the websites or apps of our partner networks, advertisers and affiliates (including, but not limited to, websites on which the Platforms or the Services are advertised). If you follow a link to any of these websites, please note that these websites and any services that may be accessible through them have their own privacy policies and that We do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services, such as contact and location data. Please check these policies before you submit any personal data to these websites or use these services.

CHANGES TO PRIVACY POLICY
Any changes We may make to this privacy policy in the future will be posted on this page and, where appropriate, notified to you by SMS, e-mail or when you next access either of the Platforms. The new terms may be displayed on-screen and you may be required to read and accept them to continue your use of the Platforms.

CONTACT
Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to support@wystle.co.uk

Driver Privacy Policy

INTRODUCTION
Welcome to the Wystle driver privacy policy.
Minicabbid SVHI Limited, trading as Wystle, respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you use our [App] (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.
This privacy policy is provided in a layered format so you can click through to the specific areas set out below. (Please also use the Glossary to understand the meaning of some of the terms used in this privacy policy.)

1. IMPORTANT INFORMATION AND WHO WE ARE
2. THE DATA WE COLLECT ABOUT YOU
3. HOW IS YOUR PERSONAL DATA COLLECTED?
4. HOW WE USE YOUR PERSONAL DATA
5. DISCLOSURES OF YOUR PERSONAL DATA
6. INTERNATIONAL TRANSFERS
7. DATA SECURITY
8. DATA RETENTION
9. YOUR LEGAL RIGHTS
10. GLOSSARY

1.IMPORTANT INFORMATION AND WHO WE ARE
PURPOSE OF THIS PRIVACY POLICY
This privacy policy aims to give you information on how Wystle collects and processes your personal data through your use of our [App], including any data you may provide through our [App] when you [sign up to our newsletter, use our services, [sign up on our Website or use our Website]].
This [App] is not intended for children and we do not knowingly collect data relating to children. It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

CONTROLLER
Minicabbid SVHI Limited, trading as Wystle, is the controller and responsible for your personal data (collectively referred to as "Wystle", "we", "us" or "our" in this privacy policy). Minicabbid SVHI Limited is incorporated and registered in England and Wales with company number 09724565 and has a registered office at 3 Coombe Road, London, England, NW10 0EB.
We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.

CONTACT DETAILS
If you have any questions about this privacy policy or our privacy practices, please contact our data privacy manager in the following ways:
Full name of legal entity: Minicabbid SVHI LIMITED, trading as Wystle
Email address: [sunny@wystle.co.uk]
Postal address: [3 Coombe Road, London, England, NW10 0EB]
Telephone number:[02033273823]

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES
We keep our privacy policy under regular review. This version was last updated on [DATE]. Historic versions can be obtained by contacting us.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

THIRD-PARTY LINKS
This [App] may include links to third-party applications, websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party applications or websites and are not responsible for their privacy statements. When you leave our [App], we encourage you to read the privacy policy of every application you use, or website you visit.

2.THE DATA WE COLLECT ABOUT YOU
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
• Identity Data includes [first name, last name, username or similar identifier, marital status, title, date of birth and gender].
• Contact Data includes [billing address, delivery address, email address and telephone numbers].
• Financial Data includes [bank account number, sort code and payment card details].
• Transaction Data includes [details about payments to and from you and other details of which of our services you have used].
• Technical Data includes [internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this [App]].
• Profile Data includes [your username and password, transportation services made by you, your Driving Licence Number, [NINO], your vehicle, your vehicle tax certificate, your TFL licence, your preferences, feedback and survey responses].
• Usage Data includes [information about how you use our [App] and our services].
• Marketing and Communications Data includes [your preferences in receiving marketing from us and our third parties and your communication preferences].
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific feature of the [App]. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

IF YOU FAIL TO PROVIDE PERSONAL DATA
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.

3.HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your [Identity, Contact and Financial Data] by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
• apply for or use our services;
• create an account with us;
• subscribe to our service or publications;
• request marketing or other updates to be sent to you;
• enter a competition, promotion or survey; or
• give us feedback or contact us.
Automated technologies or interactions. As you interact with our [App], we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies[, server logs] and other similar technologies. [We may also receive Technical Data about you if you visit other websites or applications employing our cookies.] Please see our cookie policy for further details.
Third parties or publicly available sources. We will receive personal data about you from various third parties [and public sources] as set out below:
• Technical Data from the following parties:
     a. analytics providers [such as Google based outside the EU];
     b. advertising networks based [inside OR outside] the EU]; and
     c. search information providers based [inside OR outside] the EU].
• Contact, Financial and Transaction Data from providers of technical, payment and delivery services based [inside OR outside] the EU].
• Identity and Contact Data from data brokers or aggregators based [inside OR outside] the EU].
• Identity and Contact Data from publicly available sources [such as Companies House, TFL Website, Insurance Checker and the Electoral Register based inside the EU].

4.HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal obligation.
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so.
We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To register you with a Driver Account	(a) Identity (b) Contact	Performance of a contract with you
To perform our services including: (a) [Making you aware of Ride Requests and other services under our service contract] (b) [Managing the payments owed by you under the Transportation Contract between you and a Customer] (d) [Processing the payment due to you as a result of any Transportation Contract you have with a Customer] (c) [Collect and recover the Driver Fee and any other money owed to us by you]	(a) Identity (b) Contact (c) Profile (d) Marketing and Communications	• The performance of a contract with you: (a) [In our own right for the delivery of our Services; and] (b) [As your payment collection agent for the Transportation Contract you have with a Customer.] (c) [Necessary for our legitimate interests (to recover Driver Fees and any debts due to us from you).]
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey	(a) Identity (b) Contact (c) Profile (d) Marketing and Communications	•Performance of a contract with you •Necessary to comply with a legal obligation •Necessary for our legitimate interests (to keep our records updated and to study how Drivers use our services)
To enable you to partake in a prize draw, competition or complete a survey	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications	• Performance of a contract with you • Necessary for our legitimate interests (to study how Drivers use our services, to develop them and grow our business)
To administer and protect our business and this [App] (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Identity (b) Contact (c) Technical	• Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) • Necessary to comply with a legal obligation
To deliver relevant [App] content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical	• Necessary for our legitimate interests (to study how Drivers use our services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our [App], services, marketing, customer relationships and experiences	(a) Technical (b) Usage	• Necessary for our legitimate interests (to define types of Drivers for our services, to keep our [App] updated and relevant, to develop our business and to inform our marketing strategy).
To make suggestions and recommendations to you about goods or services that may be of interest to you	(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications	• Necessary for our legitimate interests (to develop our services and grow our business).

MARKETING
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

PROMOTIONAL OFFERS FROM US
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving that marketing.

THIRD-PARTY MARKETING
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

OPTING OUT
You can ask us or third parties to stop sending you marketing messages at any time [by contacting us at any time].
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of service purchase, service experience or other transactions.

COOKIES
You can set your browser to refuse all or some browser cookies, or to alert you when applications or websites set or access cookies. If you disable or refuse cookies, please note that some parts of our [App] may become inaccessible or not function properly. For more information about the cookies we use, please see Cookie Policy].

CHANGE OF PURPOSE
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5.DISCLOSURES OF YOUR PERSONAL DATA
We may share your personal data with the parties set out below for the purposes set out in the table above.
• Internal Third Parties as set out in the [Glossary]
• External Third Parties as set out in the [Glossary]
• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6.INTERNATIONAL TRANSFERS
We may transfer your personal data outside the European Economic Area (EEA).

7.DATA SECURITY
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8.DATA RETENTION
HOW LONG WILL YOU USE MY PERSONAL DATA FOR?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
By law we have to keep basic information about our customers, which includes drivers who use our service (including Contact, Identity, Financial and Transaction Data) for [six] years after they cease being customers for [tax] purposes.
In some circumstances you can ask us to delete your data: see below for further information.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

9.YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:
• [Request access to your personal data].
• [Request correction of your personal data].
• [Request erasure of your personal data].
• [Object to processing of your personal data].
• [Request restriction of processing your personal data].
• [Request transfer of your personal data].
• [Right to withdraw consent].
If you wish to exercise any of the rights set out above, [please contact us]

NO FEE USUALLY REQUIRED
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

WHAT WE MAY NEED FROM YOU
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

TIME LIMIT TO RESPOND
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

THIRD PARTIES
• Service providers [acting as processors] who provide [IT and system administration services].
• Professional advisers [acting as processors or joint controllers] including lawyers, bankers, auditors and insurers who provide [consultancy, banking, legal, insurance and accounting services].
• HM Revenue & Customs, regulators and other authorities [acting as processors or joint controllers] based [in the United Kingdom] [who require reporting of processing activities in certain circumstances].
• [ADD DETAILS OF ANY OTHER THIRD PARTIES, FOR EXAMPLE, MARKET RESEARCHERS, FRAUD PREVENTION AGENCIES, PRICE COMPARISON SITES AND SO ON.]

YOUR LEGAL RIGHTS
1. Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
2. Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
3. Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
4. Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
5. Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
(a) If you want us to establish the data's accuracy.
(b) Where our use of the data is unlawful but you do not want us to erase it.
(c ) Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
(d) You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
6. Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
7. Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.

Customer Privacy Policy

INTRODUCTION
Welcome to the Wystle customer privacy policy.
Minicabbid SVHI Limited, trading as Wystle, respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you use our [App] (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.
This privacy policy is provided in a layered format so you can click through to the specific areas set out below. (Please also use the Glossary to understand the meaning of some of the terms used in this privacy policy.
1. IMPORTANT INFORMATION AND WHO WE ARE
2. THE DATA WE COLLECT ABOUT YOU
3. HOW IS YOUR PERSONAL DATA COLLECTED?
4. HOW WE USE YOUR PERSONAL DATA
5. DISCLOSURES OF YOUR PERSONAL DATA
6. INTERNATIONAL TRANSFERS
7. DATA SECURITY
8. DATA RETENTION
9. YOUR LEGAL RIGHTS
10. GLOSSARY

1. IMPORTANT INFORMATION AND WHO WE ARE
PURPOSE OF THIS PRIVACY POLICY
This privacy policy aims to give you information on how Wystle collects and processes your personal data through your use of our [App], including any data you may provide through our [App] when you [sign up to our newsletter, use our services, [use our Website or Sign up on our Website]].
This [App] is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

CONTACT DETAILS
If you have any questions about this privacy policy or our privacy practices, please contact our data privacy manager in the following ways:
Full name of legal entity: Minicabbid SVHI Limited, trading as Wystle
Email address: sunny@wystle.co.uk
Postal address: Unit 8, Maple Grove Business Centre, Hounslow, London, TW4 6DR
Telephone number: 02033273823
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues ( www.ico.org.uk ). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

2. THE DATA WE COLLECT ABOUT YOU
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
• Identity Data includes [first name, last name, username or similar identifier, marital status, title, date of birth and gender].
• Contact Data includes [billing address, delivery address, email address and telephone numbers].
• Financial Data includes [bank account and payment card details].
• Transaction Data includes [details about payments to and from you and other details of which of our services you have used].
• Technical Data includes [internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this [App]].
• Profile Data includes [your username and password, [Ride Requests] made by you, your interests, preferences, feedback and survey responses].
• Usage Data includes [information about how you use our [App] and our services].
• Marketing and Communications Data includes [your preferences in receiving marketing from us and our third parties and your communication preferences].
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific feature of the [App]. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

3.HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your [Identity, Contact and Financial Data] by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
• apply for or use our services;
• create an account with us;
• subscribe to our service or publications;
• request marketing or other updates to be sent to you;
• enter a competition, promotion or survey; or
• give us feedback or contact us.
Automated technologies or interactions. As you interact with our [App], we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies[, server logs] and other similar technologies. [We may also receive Technical Data about you if you visit other websites or applications employing our cookies.] Please see our cookie policy for further details.
Third parties or publicly available sources. We will receive personal data about you from various third parties [and public sources] as set out below:
• Technical Data from the following parties:
a. analytics providers [such as Google based outside the EU];
b. advertising networks [such as [INMOBI] based [inside OR outside] the EU]; and
c. search information providers [such as [GOOGLE, FACEBOOK] based [inside OR outside] the EU].
• Contact, Financial and Transaction Data from providers of technical, payment and delivery services [such as [WORLDPAY] based [inside OR outside] the EU].
• Identity and Contact Data from data brokers or aggregators based [inside OR outside] the EU].
• Identity and Contact Data from publicly available sources [such as Companies House and the Electoral Register based inside the EU].

4. HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal obligation.
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To register you with a Driver Account	(a) Identity (b) Contact	Performance of a contract with you
To perform our services including: (a) [Making you aware of Ride Requests and other services under our service contract] (b) [Managing the payments owed by you under the Transportation Contract between you and a Customer] (d) [Processing the payment due to you as a result of any Transportation Contract you have with a Customer] (c) [Collect and recover the Driver Fee and any other money owed to us by you]	(a) Identity (b) Contact (c) Profile (d) Marketing and Communications	• The performance of a contract with you: (a) [In our own right for the delivery of our Services; and] (b) [As your payment collection agent for the Transportation Contract you have with a Customer.] (c) [Necessary for our legitimate interests (to recover Driver Fees and any debts due to us from you).]
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey	(a) Identity (b) Contact (c) Profile (d) Marketing and Communications	•Performance of a contract with you •Necessary to comply with a legal obligation •Necessary for our legitimate interests (to keep our records updated and to study how Drivers use our services)
To enable you to partake in a prize draw, competition or complete a survey	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications	• Performance of a contract with you • Necessary for our legitimate interests (to study how Drivers use our services, to develop them and grow our business)
To administer and protect our business and this [App] (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Identity (b) Contact (c) Technical	• Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) • Necessary to comply with a legal obligation
To deliver relevant [App] content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical	• Necessary for our legitimate interests (to study how Drivers use our services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our [App], services, marketing, customer relationships and experiences	(a) Technical (b) Usage	• Necessary for our legitimate interests (to define types of Drivers for our services, to keep our [App] updated and relevant, to develop our business and to inform our marketing strategy).
To make suggestions and recommendations to you about goods or services that may be of interest to you	(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications	• Necessary for our legitimate interests (to develop our services and grow our business).

MARKETING
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

THIRD-PARTY MARKETING
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

CHANGE OF PURPOSE
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5.DISCLOSURES OF YOUR PERSONAL DATA
We may share your personal data with the parties set out below for the purposes set out in the table above.
• Internal Third Parties as set out in the [Glossary]
• External Third Parties as set out in the [Glossary]
• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6.INTERNATIONAL TRANSFERS
We do not transfer your personal data outside the European Economic Area (EEA).

7. DATA SECURITY
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. DATA RETENTION
HOW LONG WILL YOU USE MY PERSONAL DATA FOR?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for [six] years after they cease being customers for [tax] purposes.
In some circumstances you can ask us to delete your data: see your legal rights below for further information.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

9.YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data.
• [Request access to your personal data].
• [Request correction of your personal data].
• [Request erasure of your personal data].
• [Object to processing of your personal data].
• [Request restriction of processing your personal data].
• [Request transfer of your personal data].
• [Right to withdraw consent].
If you wish to exercise any of the rights set out above, [please contact us]

10. GLOSSARY
LAWFUL BASIS
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to. THIRD PARTIES
• Service providers [acting as processors] who provide [IT and system administration services]. • Professional advisers [acting as processors or joint controllers] including lawyers, bankers, auditors and insurers who provide [consultancy, banking, legal, insurance and accounting services]. • HM Revenue & Customs, regulators and other authorities [acting as processors or joint controllers] based [in the United Kingdom] [who require reporting of processing activities in certain circumstances].

Privacy policy

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