Privacy Policy for Drivers

Greece

Privacy Policy pursuant to Regulation (EU) 2016/679 (“General Data Protection Regulation” or “GDPR“) and Data Protection Law 4624/2019 (”Greek Data Protection Law”) for Users of the FREE NOW Driver App

Version: September 2023

The information provided below gives you an overview over the processing of your personal data by us and your rights under data protection law applicable in Hellenic Republic (“Greece”) in connection with the use of our app for procuring Journeys for Drivers (“FREE NOW Driver App”).

Which of your personal data is processed is substantively determined based on the services or products you use.

Table of Contents

Information Regarding the Data Controller
Definitions
Data Processing Activities and Purposes
Data Exchange within the FREE NOW Group
Processing in-/outside of the European Union / European Economic Area
Your Rights
Data Security
Storage Period
Updates and Changes

1. Information Regarding the Data Controller

For Drivers in Greece the data controller as per Art. 4 No. 7 GDPR is:

FREE NOW HELLAS SINGLE MEMBER SOCIETE ANONYME (“FREE NOW“)

115 Kifissias Avenue,11524 Attica, Athens, Greece

The data controller has a data protection officer. The easiest way to reach our data protection officer is via: https://support.free-now.com/hc/requests/new or by writing to the foregoing address with the subject: “The Data Protection Officer.”

2. Definitions

“Personal data” is all information which relates to an identified or identifiable natural person. Among these are, for example, name, postal address, e-mail address or telephone number, but also usage data like your IP address.

“FREE NOW Group” consists of Intelligent Apps GmbH, mytaxi Austria GmbH, mytaxi Network Ireland Ltd., mytaxi Italia Sr., mytaxi Polska Sp.z.o.o, mytaxi Iberia S.L. , Transcovo SAS, Transopco France SAS, Transopco UK Ltd., FREE NOW Portugal Unipessoal Lda, Free Now Hellas Single Member Societe Anonyme.

“Processing” is every process carried out with or without automated assistance or every sequence of such processes in connection with personal data, e.g. obtaining, capturing, organising, ordering, saving, adjusting or modifying, sorting, accessing, using, disclosing by transmission, distributing or any other form of making available, comparing or connecting, limiting, deleting or destroying.

“Journey” is every tour intermediated between a Passenger and a Driver through the FREE NOW Driver application.

“Passengers” are the natural persons who receive mediation services from our Company through our Application for drawing up transportation contracts with Drivers.

“Drivers” are the natural persons who receive mediation services from our Company through our Application for drawing up transport contracts with Passengers.

A "controller" of personal data is the organization or person who decides how and why personal data will be processed – either alone or jointly with others.

"Taxi Owners" are the natural or legal persons who are licensed to own taxis for their commercial exploitation.

3. Data Processing Activities and Purposes

Below, we will inform you about the various types of personal data we process and for what purpose(s). The FREE NOW Driver App makes it possible for you to procure Journeys through us with Passengers. For the use of our FREE NOW Driver App for procurement of Journeys, you must provide personal data which we process in order to perform the respective service. If additional information can be voluntarily shared, these are indicated as being “optional“.

3.1. Journey Procurement

To procure journeys through us, the following personal data is processed:

3.1.1. General including on-boarding

To register for use of the FREE NOW Driver App, you must provide the following information:

First name and surname, date of birth, city, country, e-mail address, fax number, mobile phone number, information regarding your license, your GPS coordinates while being logged in to the FREE NOW Driver App and the same at time of booking, at the start, during the course of and at the destination of a particular Journey, information regarding your end user device (Device ID, time of access of the FREE NOW Driver App, browser type and operating system), information regarding the Transportation Company (for Drivers who are employees), company address (for Drivers who are, at the same time, sole proprietors), statements regarding ratings by Passengers (1 to 5 stars for the Driver and the vehicle as well as the average rating), license plate number, color and make of the vehicle, readiness status, user ID, number of Journeys, revenue, rate of concluding or breaking off Journeys, statements regarding payment by the Passenger including tips and, in encrypted form, the password you have selected, profile picture (optional input).

If you have registered with the FREE NOW Driver App, but have not completed the Driver on-boarding process, we may contact you using the email address that you provided during the registration process to remind you that the on-boarding is not yet complete. We rely on our legitimate interests [(Art. 6 (1) f) GDPR)] in resourcing our business (and/or your consent, where provided) to carry out this processing.

You can consent to the usage of your GPS coordinates by FREE NOW during the installation of the FREE NOW Driver App. Via the operating system of your end user device (smartphone, tablet, etc.), you can also consent to the usage of your GPS coordinates by FREE NOW at a later point in time or withdraw your consent. In the absence of you sharing your GPS coordinates with us, we cannot procure Journeys for you or, as it may be, for your Transportation Company, since we communicate Passenger requests based on location in order to arrive at a short time delay until arrival.

For purposes of identification, we show your GPS coordinates as well as your name and, insofar as it has been provided to us, your profile picture and the license plate number to the Passenger who has booked a Journey with you. After accepting the Journey, during the Journey and for a certain period of time after the conclusion of the Journey, the Passenger is able to call you via the FREE NOW Passenger App. For this, we are using a phone number masking service (see point 3.1.2). In this way the Passenger can still call you after a Journey in order to ask, for example, about items forgotten in the vehicle but is not able to see your phone number at any time.

Without the processing of the foregoing personal data, we cannot procure any Journeys for you through your Transportation Company. This does not apply to optional inputs.

When passengers book a tour in your area, we display your picture, name and average rating while arranging the tour. The passenger has no possibility to prefer a specific driver based on this information. The processing is based on the legitimate interest to present the tour arrangement process to the passenger in a more personalised and transparent way. You can object to this process using the contact information provided here, so that your information will not be displayed in such a case.

3.1.2. Multi-factor authentication and phone number masking via Twilio

For security reasons, when you register for the first time or log in from a new mobile device in the FREE NOW Driver App, we verify your registration with a code via SMS or email ("multi-factor authentication"). We use the service provider Twilio Inc. 375 Beale St, Suite 300 San Francisco, CA 94105, USA ("Twilio") to send the SMS. In order to best protect your data, we also use Twilio's calling service to mask your phone number to the relevant passenger. The passenger will still be able to call you (via Twilio) but will not know your phone number.

Legal basis to use the services of Twilio is our legitimate interest pursuant to Art. 6 (1) f) GDPR to improve the security of our services.

We have entered into a data processing agreement with Twilio to ensure that your personal data will only be processed in accordance with our instructions and with applicable data protection law. The lawfulness of the data transfer to the USA is ensured by Twilios' binding corporate rules according to Art. 47 GDPR. Additionally, standard contractual clauses (SCCs) have been concluded. Further information on the privacy settings of Twilio can be found at www.twilio.com/legal/privacy.

3.1.3. Contact with FREE NOW

FREE NOW provides several means of contact for its customers such as our online contact form: https://support.free-now.com/hc/requests/new. You can further contact FREE NOW per letter or phone. Whenever you get in touch with FREE NOW, we store and process your personal data.

Depending on the means of contact you chose, FREE NOW is processing the following of your personal data:

name, e-mail address, country, phone number, voice recordings, content of your messages, attachments

Legal basis for this processing generally is our legitimate interest, according to Art. 6 (1) f) GDPR, in responding to your messages. When you initiate a contact in order to enter into a contract or because of a contract with FREE NOW, the legal basis is Art. 6 (1) b) GDPR.

To use our online form you are only required to provide us with your e-mail address for us to respond to your message. Communication with FREE NOW is deleted after 3 years, based on our legitimate interest, Art. 6 (1) f) GDPR, for the establishment, exercise or defence of legal claims.

When calling FREE NOW your phone call may be recorded, based on the necessity to perform the contract we have with you. The purpose for recording the calls is fraud prevention, GDPR consent verification and documenting violations of our Terms and Conditions. Call recordings get automatically deleted after 90 days.

Parts of your communications with FREE NOW concerning individual passengers may be subject to disclosure to those passengers exercising their rights under Art. 15 (Right of Access) of the GDPR. Where FREE NOW receives such a request, it will either seek your consent to disclose any information which identifies you or where it is reasonable to comply with the request without your consent (such as when the passenger is already aware of your identity), FREE NOW will take steps to minimise and redact information about you.

In order to offer our best service to you, we are working together with Zendesk, Inc. 1019 Market Street, San Francisco, CA 94103, US. The transmission of your personal data is secured by Standard Contractual Clauses and Binding Corporate Rules in accordance with Art. 46 GDPR.

Learn more about Zendesk and their commitment to the protection of personal data at https://www.zendesk.com/company/privacy-and-data-protection.

3.1.4. Integration of Google Maps

The FREE NOW Driver App uses the Google Maps API which is provided by Google Ireland Limited Gordon House, Barrow Street Dublin 4 (“Google”). In this way, you can be shown maps in the FREE NOW Driver App and you can also have the ability to interact with said maps. Without the Google Maps API application, FREE NOW Driver App will not function. The terms of use for Google Maps can be found at: https://www.google.com/help/terms_maps.html. There, you will also find a notice regarding the privacy policy of Google: https://policies.google.com/privacy?hl=de. We use Google Maps in order to calculate the anticipated cost of the Journey and in order to interactively show you the distance to the Passenger who booked the Journey. We process your GPS coordinates in accordance with Art. 6 (1) f) GDPR, if you have agreed to the usage. Your GPS coordinates will only be transmitted to Google in an anonymised manner. An identification of your person is impossible.

3.1.5. To facilitate the provision of our B2B service (“FREENOW XL”)

FREE NOW, as part of its services, provides, through a special “Web Booker” platform, B2B corporate solutions to partner hotel companies that will act as intermediaries for the provision of predetermined itineraries. In the context of this service, the passengers have the option to book in advance appointments “FREENOW XL”, namely large vehicles with 6-8 passenger seats, through their Accommodation Hotel Reception. For this service, FREE NOW is acting as a mediator and processes the data of both Drivers and Passengers as a data controller. The cooperating hotel companies have the status of a third party recipient in the context of the above processing of personal data.

Categories of personal data used for this purpose are the information of their vehicle fleet (details of each vehicle), routes (boarding address, destination, duration, route distance, boarding and disembarking time) and values of the routes they have performed, tips, bonus and toll charges, but also tax data (the income of Drivers with period filter).

Our lawful basis for processing this personal data: FREE NOW processes the data of the drivers for the purposes of the timely and appropriate provision of the taxi service, and compliance with tax obligations. The Operators as taxi owners act as third party recipients of the drivers' data for the purposes of executing the brokerage contract and complying with tax legislation.

The issuance of an invoice for the said service is carried out by the Driver.

Similar to the tours booked through the app, when passengers book a tour through their Accommodation Hotel, we display your picture, name and communication details in order to facilitate your communication with the passenger. The passenger has no possibility to prefer a specific driver based on this information. The relevant processing is based on the legitimate interest to present the tour arrangement process to the passenger in a more personalised and transparent way. You can object to this process using the contact information provided here, so that your information will not be displayed in such a case.

3.1.6. To provide the "Portal" service

FREE NOW processes the personal data of Drivers in its capacity as data controller for the provision of FREE NOW Portal services to Taxi Owners.

Legal basis for the processing of this personal data: our legitimate interest in accordance with Article 6 §1 (f) GDPR to improve our services and provide Taxi Owners with appropriate and valid information.

3.1.7. To provide the "Weekly Reports" service

Finally, the weekly report ("Weekly Report") is drawn up as an accompaniment to the invoices, which is sent to each Taxi Owner and includes the following data: Drivers’ routes with their corresponding value and the relative commission.

In the context of these weekly reports, FREE NOW processes the data of the Drivers as a data controller in accordance with Article 6 §1 (f) GDPR for the purposes of evaluating their turnover within the Platform, while transmitting it to the Taxi Owners as third-party recipients for the purposes of managing their businesses and checking their compliance with their tax obligations.

Categories of personal data used for this purpose: Drivers’ routes (boarding address, destination, duration, route distance) with their corresponding value and the relative commission.

3.2. Payment

In order to make it possible to conduct payment pursuant to the respectively applicable “FREE NOW Procurement Framework Agreement” and the respectively valid “Terms and Conditions for Taxi Companies”, the following personal data will be processed pursuant to Art. 6 (1) b) GDPR for the purpose of performance of the contract:

Your first name and surname, the number of Journeys, revenue and, if you are yourself a Transportation Company, information regarding payments and bank account.

3.3. Rating of Drivers and Passengers

Via the FREE NOW Passenger App, Passengers can rate you and your vehicle after a Journey with between 1 to 5 stars. The individual rating flows into the average value which we have determined for you and your vehicle. The individual rating is only visible to the respective Passenger who provides it, to you as the Driver and to FREE NOW. For Drivers who are employed with a Transportation Company, we only transmit the individual rating to your Transportation Company with your consent.

Further, Passengers can add Drivers as favorite Drivers in their FREE NOW Passenger App profiles. In this context, your first name and surname, your rating and the profile picture will be saved in the FREE NOW Passenger App of the respective Passenger.

The processing of this data takes place on the basis of our legitimate interest pursuant to Art. 6 (1) f) GDPR to ensure a reasonable standard of quality and ensure Passenger security.

Beyond this, you have the possibility of rating Passengers. The ratings are only visible to FREE NOW and will only be transmitted to the affected Passenger upon request in an anonymised form. The processing of personal data by FREE NOW will take place on the basis of your consent pursuant to Art. 6 (1) a) GDPR which you have given by providing a rating.

3.4. Fraud Prevention

3.4.1 General

FREE NOW is invested to make its platform a secure space for passengers and drivers. Therefore, FREE NOW has implemented measures to detect and prohibit fraudulent behaviour in order to protect passengers and drivers. Also, FREE NOW wants to reduce the risk of financial damages due to fraudulent behaviour. For this reason FREE NOW will conduct an evaluation of risk for fraudulent behaviour on the basis of a mathematical-statistical model (scoring). This processing is based on the abovementioned legitimate interest pursuant to Art. 6 (1) f) GDPR.

To determine the score, the following personal data will be processed:

Passenger and Driver data such as: phone number, email address, name, device identifiers,
Tour data such as: length of the tour, distance to the passenger, used incentives, tour value, starting location and destination location,
Payment data such as: payment method.

The values stemming from this data are compared to a set of previously defined scenarios that indicate fraudulent behaviour. Based on the number of scenarios that we identify, our European fraud prevention service provider will calculate a score revealing the likelihood of fraudulent behaviour. Based on that score a specially trained FREE NOW employee will further investigate if there can be any confirmation of fraudulent behaviour. The score will not be used for any automated decision-making. Any actions taken will never be justified by the score and will always involve human oversight.

3.4.2 GPS Tracking

In order to prevent fraudulent activity, we store your GPS location data sent to us by your mobile device at short intervals from the time of acceptance until the end of a tour. This allows FREE NOW to create a map of the entire course of a tour. In this way, we want to ensure that drivers do not deliberately extend the route in order to achieve a higher fee. At the same time, we can rectify unjustified passenger complaints by being able to follow the actual course and route to a tour. The processing of your GPS location data during a tour takes place for your own protection, as well as for the protection of the passenger and for our protection on the basis of Art. 6 (1) f) GDPR.

3.5. Bug Fixing and Functionality Improvements

In order to fix bugs in the FREE NOW Driver App and to improve functionality of the FREE NOW Driver App and to adjust it to suit the needs of Drivers, we process the following personal data pursuant to Art. 6 (1) f) GDPR on the basis of our legitimate interest:

First name and surname, date of birth, city, country, e-mail address, fax number, mobile phone number, information regarding your license, your GPS coordinates while being logged into the FREE NOW Driver App and at the time of booking, time of starting and during the course and at the destination of a particular Journey, information regarding your end user device (Device ID, time of access of the FREE NOW Driver App, browser type and operating system), information regarding the Transportation Company (for Drivers who are not themselves Transport Companies), company address (for Drivers who are, at the same time, Transportation Companies), information regarding the rating of Passengers (1 to 5 stars for the Driver and the vehicle as well as the average rating), license plate, color and make of the vehicle, readiness status, user ID, number of Journeys, revenue, rate of concluding or breaking off Journeys, statements regarding payment by the Passenger including tips and, in encrypted form, the password you have selected.

Inasmuch as it is sufficient for the performance of the respective purpose, we work with anonymous data and not with personal data.

To improve our response time to errors within the FREE NOW app and to improve the performance of our app, we work with the service provider DataDog Inc, New York Times Bldg, 620 8th Ave, Fl 45, New York, NY 10018, USA. All data processed by Datadog is automatically deleted after a maximum of 30 days.

Transfers of personal data to Apptimize and Datadog are secured by standard contractual clauses according to Art. 46 GDPR, providing an adequate level of data protection.

You can object to this processing by contacting us at https://support.free-now.com/hc/requests/new.

3.6. News & Personalised Offers

3.6.1. General

When you provide FREE NOW the permission to send push notifications during FREE NOW Driver App installation, FREE NOW will send you push notifications based on your provided consent. This consent is overridden if, in the context of the registration process or later in the profile of the FREE NOW Driver App under the rubric “Privacy“, consent is given to receive news & personalized offers (advertising, coupons and special offers) and to show usage-based advertising („Retargeting“), and the correspondingly placed toggle has been activated, you will receive offers and advertising from us, and also for products and services of other companies of the FREE NOW Group. In this respect, your end user device (smartphone, tablet, PC, etc.) will receive personalized advertisements via electronic post (e-mail, SMS, MMS) or by another electronic means (via in-app messages, push messages).

In connection with this, we process the following personal data pursuant to Art. 6 (1) a) GDPR, insofar as you have given us the corresponding consent:

First name and surname, driver ID, e-mail address, business address, mobile phone number, profile picture (optional input), registration data, language setting, type of Journey (booking, try-out ride), version of the FREE NOW Driver App, login information, your GPS location data at the time of the booking and at the time of the end of the Journey or, as it may be, the pickup and destination locations, device ID (device identifier), IDFA (advertising identifier Apple Identifier for Advertisers), IFV (advertising identifier, Identifier Vendor), GAID (Google Advertising Identifier), IP address and usage data (usage frequency, information relating to the downloading of the FREE NOW Driver App, status of the registration of Journeys), language, time zone and city.

If you do not wish to receive the foregoing stated news & personalized offers, you can – just as easily as you consented – withdraw your consent by activating the corresponding toggle. Of course, you can also contact us via https://support.free-now.com/hc/requests/new or send us a letter by post to our address provided at the top of this policy.

Please note that the withdrawal and ensuing changes are valid only for the future and will be effective or, as it may be, implemented by no later than 48 hours from withdrawal. This is for reasons of a technical nature, which do not permit faster implementation.

3.6.2. Direct Advertising for Existing Customers

If, in connection with the performance of our procurement services, we have received your e-mail address or mobile phone number and you have completed at least one Journey which we procured, we will use these exclusively for our own direct advertising of our own products and services via electronic post (e-mail, SMS and MMS), unless you have rejected such direct advertising. To this purpose, on the basis of our legitimate interest pursuant to Art. 6 (1) f) GDPR, we process the following data: e-mail address and mobile phone number. Our legitimate interest lies in intensifying customer relationships by proposing appropriate and interesting product information. The objection to direct advertising is possible at any time with effect for the future by clicking on the corresponding link in a relevant e-mail (e.g. to unsubscribe to a newsletter) or by contact via SMS. The direct advertisement sent by us is not personalized. Please take into account that the objection and the modifications required thereby are valid only for the future and will be effective or, as it may be, implemented by no later than 48 hours from withdrawal. This is for reasons of a technical nature, which do not permit faster implementation.

3.6.3. Usage of the AppsFlyer Technology

We use the services of the provider AppsFlyer Ltd., 14 Maskit St., Herzliya, Israel ("AppsFlyer") to learn in which ways Drivers become aware of our App and use it. In this context, certain information is collected, processed and used regarding the devices used by the Drivers, their online usage behavior and the contents of websites they visit. In particular, this includes information regarding:

individual user identifiers such as IP address, user agent, IDFA (Identifier for Advertisers), Android ID (in Android devices), Google Advertiser ID and AppsFlyer ID.
Technical data such as Android ID, information regarding the operating system of the used device, user agent identification, device model, browser language, TourID, eventName, eventValue, events_api, city, device information and settings, applications, opt out declarations regarding advertising measures, downloads, website hits, clicks and installations of apps, in-app behavior, device motion parameters, network carrier, events that occur outside of the mobile app (server-to-server events), association of in-app events, as well as original device and attributed media sources recorded by AppsFlyer.

AppsFlyer uses these data on our behalf to evaluate and analyze the performance of our marketing measures and channels and to determine how Drivers respond to specific campaigns, how they use the app and interact with it. The foregoing described data is not used to individualize individual users or to associate them with a specific person. Additionally, the data are used to uncover and prevent cases of so-called “mobile fraud“, i.e. manipulating and fraudulent actions in connection with our marketing measures. On the basis of the collected data which are aggregated in the course of the process, AppsFlyer can identify for us if certain actions relating to our app (e.g. download or installation) were caused by manipulation. This also serves our business interests as we have to consider such mobile fraud actions in the compensation of our cooperating partners (advertising networks/partner websites which display our advertisements). Further information regarding the treatment of your data by AppsFlyer can be reviewed at https://www.appsflyer.com/services-privacy-policy. The data processing occurs, therefore, on the basis of the so-called balancing of interests clause in Art. 6 (1). (f) GDPR and in the context of our foregoing described legitimate interest.

If you do not wish for the use of AppsFlyer technology, please write to us via https://support.free-now.com/hc/requests/new.

3.6.4. Sending news and service communications

For sending news, service communication and advertising e-mails, SMS and in-app messages, we make use of the service provider Braze Inc., 330 West 34th Street, New York, NY 10001, USA (“Braze”). For sending service communications, we make use of the service provider “MailChimp“, which is operated by Rocket Science Group, LLC, 675 Ponce De Leon Ave NE, Suite 5000, Atlanta, GA 30308, USA.

The personal data processed includes

contact data, e.g. e-mail address, phone number, name
location data, e.g. language, country, city
content data, e.g. tour data, incentives data
usage data, e.g. log-in times, log-out times

We have concluded data processing agreements with our service providers which ensures that the service provider exclusively processes your personal data pursuant to our instructions and in accordance with current data protection law.

We have concluded standard contractual clauses (SCCs) with Braze and Mailchimp in accordance with Art. 46 GDPR to ensure an adequate level of data protection when processing your data.

The legal basis for the transmission of data and its processing by our service providers is Art. 6 (1) f) GDPR in connection with Art. 28 GDPR. Our legitimate interest in the engaging of these service providers lies in the professional and reasonable organization of automated processes in an economically sensible way which makes it possible to provide you a positive user experience.

You can object to data processing at any time by sending a message via https://support.free-now.com/hc/requests/new.

3.6.5. Facebook Custom Audiences

In order to be able to display individually targeted advertisements about our services within the Facebook social network, a service of Facebook Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland (“Facebook”), and on Facebook partner sites, we work with Facebook Custom Audiences. We do this so that advertisements (e.g. banners) can be tailored exactly to the possible needs of the customer. The basis of this is a marking process. In this context, the so-called advertising identifier (IDFA or GAID) from the customer’s end user device (e.g. smartphone) is sent automatically or manually, using a service provider selected by FREE NOW, to Facebook via a certain interface. The advertising identifiers are individual, but not personalized and not permanent identification numbers for a certain end user device which are provided by iOS or, as it may be, Android. You can prevent the transmission of advertising identifiers if, in iOS under “Settings” – “Data Protection” – “Advertising”, you select the option “no ad tracking” or, as it may be, for Android, under “Settings” – “Google” – “Advertising” select the option “deactivate personalized advertising.” Further, you have the option to delete the advertising identifier at any time in the device settings (iOS: “Reset Ad-ID”; Android: “Reset Advertising-ID”). Then, a new identification number will be generated for your device which will not be aggregated with the previously obtained data for your device. After the transmission of the advertising identifiers, FREE NOW will prepare a list of customers who have performed certain actions using the FREE NOW Driver App. In this context, certain pre-defined actions can be selected (e.g. installation of the FREE NOW Driver App in the previous 30 days). Facebook compares the advertising identifier of the customer with the advertising identifier of individuals with a Facebook profile, defines certain groups (e.g. Group 1: Installation in the previous 30 days) and then shows appropriate ads to this group. Facebook can also use the data to select other Facebook users whose statistical behaviors are similar to those of our customers or app users (so called statistical twins, called Lookalike Audience by Facebook). In this way, our advertising can reach individuals who are not yet using our services but who, with a high likelihood, would be interested in doing so. Customers who are not, at the same time, Facebook users, cannot however be compared by Facebook and they are not shown any advertisements. Furthermore, conditioned upon your consent, we can manually transmit your e-mail address in an encrypted form to Facebook (so called hash procedure). Facebook then compares whether the transmitted e-mail address corresponds with existing Facebook customers. If there is a correspondence, then these target groups will be shown targeted advertisements/campaigns by FREE NOW on Facebook or on partner websites of Facebook. In connection with Facebook Custom Audiences, we process the following data pursuant to Art. 6 (1) a) GDPR: web identifier (IDFA for Apple or GAID for Google) and the e-mail address.

If you no longer wish for your data to be processed in connection with Facebook Custom Audiences, you can – just as easily as when you gave consent – withdraw your consent in the “Data Protection Settings“ of the FREE NOW Driver App *(under the option “Profile“) by turning off the toggle relating to “Personalized Advertising”. Naturally, you can also send us a message via https://support.free-now.com/hc/requests/new or send us a letter by post to our address provided at the top of this policy.

Please note that the withdrawal and the thereupon ensuing changes are valid for the future and will be effective or, as it may be, implemented by no later than 48 hours from the withdrawal. This is for reasons of a technical nature, which do not permit faster implementation.

3.6.6. Mobile Attribution Tracking

We make use of the service providers Pinterest (Pinterest Europe Ltd, Palmerston House, 2nd Floor, Fenian Street, Dublin 2, Ireland; "Pinterest"), Snapchat (Snap Group Ltd, 77 Shaftesbury Avenue, London, W1D 5DU, United Kingdom; "Snapchat"), Twitter (Twitter International Company, One Cumberland Place, Fenian Street, Dublin 2, D02 AX07, Ireland; "Twitter") and AdTriba (AdTriba GmbH, Beim Schlump 13a, 20144 Hamburg, Germany; „AdTriba“) to deploy marketing campaigns according to demand, further optimize them and measure their reach. In this way, we ensure that the respective marketing campaigns are only displayed to users who have also shown an interest in our FREE NOW offers and that our marketing campaigns therefore correspond to the potential interest of the respective user. In addition, we can track the behavior of users after they have clicked on one of our FREE NOW marketing campaigns. This helps us measure the reach of each campaign for statistical, market-related and internal billing purposes.

The following data are processed:

Device information (e.g. type, brand), Advertising Identifiers (IDFA), operating system used, IP address, timestamp of the call to our offer, type and content of the campaign and the click behaviour in relation to a campaign.

The processing is carried out on the basis of legitimate interests for behaviour- and interest-based advertising in accordance with Art. 6 (1) f) GDPR in conjunction with Recital 47 to the GDPR. If you are logged in at the same time with your user account, the respective service provider is able to link this data to your user account and use it for its own advertising purposes. Further information can be found in the respective privacy policy.

Pinterest: https://policy.pinterest.com/en-gb/privacy-policy

Snapchat: https://www.snap.com/en-GB/privacy/privacy-policy

Twitter: https://twitter.com/en/privacy

AdTriba: https://privacy.adtriba.com

You can object to data processing at any time by deactivating the relevant settings in your user account. If you wish to object to our data processing in connection with our Mobile Attribution Tracking, you can do so at any time by sending a message via https://support.free-now.com/hc/requests/new.

3.7. Studies & Surveys

3.7.1. General

If you have consented in the course of the registration process or, later, in the profile of the FREE NOW Driver App under “Data Protection“, to receive studies & surveys, and have activated the corresponding toggle, we will contact you after a Journey or at some other time in the context of personalized (sent only to you and based on an analysis of the FREE NOW Driver App usage frequency) studies & surveys sent by electronic post (e-mail, SMS, MMS) or otherwise electronically (in-app messages, push messages) and request your participation. For example, we carry out quest campaigns at regular intervals, with the help of which we aim to increase and optimise the tours we arrange. In studies and surveys, the following personal data may be processed by us in accordance with Art. 6 (1) a) GDPR:

First name and surname, Driver ID, e-mail address, business address, mobile phone number, profile picture (optional input), method of payment, registration data, language set, FREE NOW Driver App profile (business or private customer), type of Journey (booking, try-out ride), FREE NOW Driver App version, login information (user name), your GPS coordinates at the time of booking and at the end of the Journey and usage data (usage frequency, information regarding the download of the FREE NOW Driver App, status of registrations or Journey), registration data, date of last login, push tokens, Device ID (device identifier), IDFA (advertising identifier, Apple Identifier for Advertisers), IFV (advertising identifier, Identifier Vendor), GAID (Google Advertising Identifier) and IP address

If you do not wish to be contacted in this regard, you can – just as easily as you gave consent – declare your withdrawal by accordingly activating the “Studies & Surveys” toggle. Of course, you can also contact us via https://support.free-now.com/hc/requests/new or send us a letter by post to our address provided at the top of this policy.

Please note that the withdrawal and ensuing changes are valid only for the future and will be effective or, as it may be, implemented by no later than 48 hours from the withdrawal. This is for reasons of a technical nature, which do not permit faster implementation. In case of withdrawal, we reserve the right to process your personal data in anonymous form for internal analysis purposes.

3.7.2. RSVPify

In order to increase the ease of scheduling appointments we use the service provided by RSVPify, LLC, 4803 N Milwaukee Ave, Suite B #325, Chicago, IL 60630, US. RSVPify is a global provider of a platform that facilitates scheduling of appointments and event management and therefore processes your personal information. RSVPify assures that they store your information securely in a globally leading cloud services infrastructure provider, using industry-compliant encryption technology.Respective to the data you voluntarily provide, the following data can be processed:

technical information (such as your internet protocol (“IP”) address, mobile device ID, or browser type) and usage information (such as location data, preferred language, the parts of the website you have visited, which links you have clicked and other information about how you interact with the Services).

Legal Basis for this processing is the performance of the contract pursuant to Art 6
(2) GDPR, or the legitimate interest of RSVPify or a third party’s legitimate interest to use personal data in such a way to ensure that RSVPify provides its services and deal with queries and enquiries in an effective, safe and efficient way.

RSVPify guarantees that the processing of personal data is subject to an adequate protection level, in that it complies with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union to the United States. RSVPify has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. Although RSVPify has continued with its Privacy Shield certification as a matter of good data privacy governance, it respects the decision of the ECJ in Case C-311/18 (“Data Protection Commissioner v Facebook Ireland Ltd, Maximillian Schrems or “Schrems II”) and applies other safeguards when it receives personal data from data controllers in the UK/ EEA including by entering into the Standard Contractual Clauses with the UK/EU data controller sending the data.

For more information regarding the processing of your personal data from RSVPify please visit: rsvpify.com/privacy/eea/

3.8. Social Media Presences

3.8.1. Facebook

When entering our Facebook-page (via a link on our website, in our newsletter or directly) you reach the technical platform provided by Facebook Ireland Ltd., 4 Grand Canal Square Grand Canal Harbour, Dublin 2, Ireland (“Facebook“). We would like to inform you that you use the Facebook-page and its functions on your own responsibility. This especially applies for the use of the interactive functions (e.g. comments, sharing, rating). During you visit on our Facebook-page, FREE NOW basically processes personal data only if you interact with us via the page, e.g. when leaving a comment, press a like-button or sending us a message. The legal basis for this processing depends on the way you use the page. If you send us a contract-related request for example, the processing is based on Art. 6 (1) (b) GDPR. Moreover, according to Art. 6 (1) (a) GDPR your data can be processed with your consent when you like or comment one of our posts or provide content on our page yourself. You can withdraw your consent any time with future effect by deleting the comment or your content. The revocation does not affect the legitimate consent-based processing that was performed until the revocation. Additionally, we analyze the visits and interactions on our page. For this Facebook creates usage profiles and provides the data in form of page-insights (“page-insights”). Page-insights are summarized data that allows us to get an overview on how users interact with our Facebook-page. For further information please visit: https://www.facebook.com/help/pages/insights. Please mind that your personal data is not only processed by FREE NOW, but also by Facebook while using and interacting with our Facebook-page. FREE NOW and Facebook are jointly responsible for the processing of insight-data. The respective responsibilities for FREE NOW and Facebook regarding the processing of insight-data are available in the page insights addendum: https://www.facebook.com/legal/terms/page_controller_addendum. How Facebook uses insight-data for its own purposes, to what extent insight data can be matched with certain users, for how long this data is stored and if data resulting from your visit on a Facebook-page is handed over to third parties is solely the responsibility of Facebook. Regarding the data processing via our Facebook-page, you can not only assert your rights under the GDPR (for further information see section 5 “Your Rights” of this document) towards FREE NOW, but also towards Facebook. Further details can be found in Facebook’s data policy under: https://www.facebook.com/about/privacy. Additional to the before-mentioned processing activities, Facebook also processes your data for analysis and advertising purposes, respectively to display personalized advertisements. According to our knowledge, Facebook makes use of cookies, pixels and other techniques which process your usage behaviour (even across different devices. This enables Facebook to display target-oriented advertisements on its own platforms and third-party websites, as well. The data collected about you in this context are transmitted to the United States of America and other non-EU countries. Which exact information Facebook receives and how it is used, is generally described in Facebook’s privacy policy. There you will also find ways to contact Facebook directly and information on settings for advertisements. The privacy policy is available under https://www.facebook.com/about/privacy . The complete privacy policy can be found here: www.facebook.com/full_data_use_policy Furthermore, Facebook offers its users the possibility to object to certain processing activities. More information on this and opt-out-possibilities can be found here: https://www.facebook.com/settings?tab=ads.

3.8.2. Links to social networks Instagram, Twitter, LinkedIn, Xing, YouTube

On our website and in our newsletters we link our accounts on other social media platforms Instagram (Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; „Instagram“), LinkedIn (LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland; „LinkedIn“); Twitter (Twitter International Company, One Cumberland Place, Fenian Street, Dublin 2, D02 AX07, Ireland; „Twitter“), YouTube (Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; „YouTube“) and Xing (New Work SE, Dammtorstraße 30, 20354 Hamburg, Germany; „Xing“) via the icon of the respective social network. When you click the links or visit our pages on the platform directly, you are on the website of the respective social media platform. The general terms and conditions and privacy policies of the respective social media network provider. We would like to inform you that we do not receive any information about the content and extent of the data processing performed by the social media network. Information on how the respective social media platform handles your data can be found in the following privacy policies:

for Instagram under http://instagram.com/about/legal/privacy/
for LinkedIn under https://www.linkedin.com/legal/privacy-policy
for Xing under

privacy.xing.com/en und https://privacy.xing.com/en/privacy-policy

for Twitter under:

twitter.com/en/privacy and https://help.twitter.com/en/rules-and-policies/twitter-cookies

for YouTube: https://policies.google.com/privacy?hl=en&gl=de

We process personal data on our social media pages as far as the user interacts with us directly, by commenting or liking our posts or sending messages. Legal basis for this kind processing is the user‘s consent according to Art. 6 (1) (a) GDPR or in case of contract-related requests Art. 6 (1) (b) GDPR. As the case may be, we share content on our social media page, if this is a function of the social media platform and communicate with you via this platform. Art. 6 (1) (1.) (f) GDPR builds the legal basis for this. The processing is performed due to a legitimate interest in public relations and communications.

4. Data Exchange within the FREE NOW Group

For internal administration and standardization purposes, we may transfer personal data of drivers or passengers within the FREE NOW Group. The legal basis for this is our legitimate interest in effective company management, Art. 6 (1) f) GDPR, see also Recital 48 to the GDPR.

4.1. Joint Controller Agreement

FREE NOW has entered into a Joint Controller Agreement according to Art. 26 GDPR with Intelligent Apps GmbH, Grosse Elbstrasse 273, 22767 Hamburg, Germany (“Intelligent Apps”). The Parties have jointly determined the order of the processing of your personal data in each section of processing.

The purpose of this agreement is to unify the handling of Driver data and billing across the entire FREE NOW Group. The Parties jointly agreed on which obligations each party fulfils under the GDPR.

Intelligent Apps GmbH is processing jointly the Drivers’ personal data of FREE NOW to improve the software of the FREE NOW Driver application and provide technical know-how to FREE NOW. FREE NOW is responsible for all data processing with regard to the local usage of the FREE NOW Driver application.

Despite the existence of a joint controllership, the Parties fulfil the obligations under data protection law in accordance with their respective competences. The Parties shall provide any information referred to in Articles 13 and 14 GDPR to you free of charge in a concise, transparent, intelligible and easily accessible form, using clear and plain language. For this purpose, each Party shall provide the other Party with all necessary information relating to their respective operating range. The Parties shall immediately inform each other about the exertion of your rights and provide the other Party with all necessary information referred to the right of access. Pursuant to Articles 15 through 22 GDPR, you may exercise your rights under the GDPR in respect of and against each of the Parties. However, to speed up the response, we would kindly ask you to contact FREE NOW to exercise your rights via https://support.free-now.com/hc/requests/new.

For more information on data processing by Intelligent Apps, please refer to the information provided in the German Privacy Policy at https://www.free-now.com/de/driver-privacy-policies/.

5. Processing in-/outside of the UK and the European Union / European Economic Area

In part, we arrange for external service providers to process your data (e.g. troubleshooting, creation of mailings). To this end it is necessary for us to transmit your personal data to our external service providers for a specified purpose (confined to the purpose in question). We have selected our service providers carefully and engaged them in writing. They are bound by our instructions and we have obtained information about their technical and organisational measures for the secure processing of personal data. We also require that our service providers comply with the applicable data protection regulations. We work with service providers from the UK, EU and EEA countries. We have concluded data processing agreements with our external service providers in accordance with Art. 28 (3) GDPR, inasmuch as this is required for the contractual purpose. The transfer to service providers outside of the European Economic Area takes place correspondingly on the basis of decisions by the EU Commission pursuant to Art. 45 GDPR respectively (an 'adequacy' decision) or on the basis of standard EU contractual clauses.

5.1. Processing of Personal Data in the UK.

As a result of Brexit, and to prepare for a possible no adequacy decision in favour of the UK, we have concluded standard contractual clauses (SCCs) with our UK location to ensure the continued legality of data transfers from the EU to the UK.

We store all our data with a cloud service provider within the EU or in IT infrastructures and systems (employee computers) at our sites outside of the EU within the UK based on the current relevant adequacy decision issued by the European Commission.

However, we do reserve the right to disclose information about you if we are legally obligated to do so or if we are asked to surrender it by administrative or law enforcement bodies (e.g. police).

6. Your Rights

You have the right to obtain confirmation as to whether or not personal data concerning you is being processed by us. Where this is the case, we will be pleased to give you access to the personal data and the information listed in Art. 15 GDPR.

In addition, you have the right to rectification (Art. 16 GDPR), the right to erasure (Art. 17 GDPR), the right to restriction of processing (Art. 18 GDPR) and the right to data portability (Art. 20 GDPR), subject to the relevant legal requirements. In addition, you have the right to object to the processing under the statutory conditions (Art. 21 GDPR) or to withdraw any consent you have given at any time with effect for the future (Art. 7 (3) GDPR).

In order to assert your rights against us, it is sufficient to send a message via https://support.free-now.com/hc/requests/new or a postal letter to the address mentioned under “1. Information regarding the Data Controller”.

In addition, you may at any time lodge a complaint with the Hellenic DPA if you are unhappy with how we have used your data. The Hellenic DPA submission portal can be accessed here and address: Hellenic Data Protection Authority, Kifissias 1-3, PC 115 23, Athens, Greece, Telephone: +30-210 6475600

7. Data Security

We have taken appropriate technical and organisational measures to guarantee data security, in particular to protect your personal data against access by third parties, as well as accidental or intentional modification, loss or destruction. Such measures are reviewed periodically and adapted in line with the state of the art. The transfer of your personal data from your end user device (e.g. smartphone) to us is always encrypted. FREE NOW is PCI DSS (Payment Card Industry Data Security Standard) certified.

8. Storage Period

The data provided by you to us is only stored for as long as is required to perform the respective purpose for which you have transmitted your data, or inasmuch as it is required for conformity with statutory or official requirements. personal data is anonymised by us, in principle, after three years, unless we have a legitimate interest in a longer storage period (e.g. bookkeeping requirements).

9. Updates and Changes

We retain the right to modify this privacy policy at any time in the future in accordance with the applicable data protection laws and regulations.

Privacy Policy for Drivers

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