Privacy Notice for Passengers (United Kingdom)
This Privacy Notice provides an overview of who FREE NOW is and how FREE NOW collects, shares and uses personal data about you when you use the FREE NOW ride-hailing app for passengers (the "App"). It also explains how you can exercise your rights under data protection law.
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The controller of the personal data we collect through the App is: Transopco UK Limited (referred to in this Notice as “FREE NOW“). FREE NOW's principal office is located at Harling House, Great Suffolk Street, London SE1 0BS. You can contact us by letter to this address.
FREE NOW has a data protection officer. You can reach our data protection officer most easily via the support page on our website available at: https://support.free-now.com/hc/requests/new. Alternatively, you can write to the address above, addressing your letter for the attention of “The Data Protection Officer.”
“Personal data” means all information which relates to an identified or identifiable living person. This means that "personal data" includes information that identifies you directly (such as your name, postal address, e-mail address and telephone number) as well as information that allows you to be identified when it is combined with other information (such as an IP address).
“Processing“ means any operation performed on personal data, whether or not those operations are automated – e.g. collecting, organising, saving and deleting personal data are all types of processing (as well as a number of other types of activity).
“Journey” is a tour requested by a passenger through the App.
A "controller" of personal data is the organisation or person that decides how and why personal data will be processed – either alone or jointly with others.
A "processor" of personal data acts on behalf of, and on the instructions of, the data controller in relation to the personal data processing.
The personal data that we collect, and how we use that data, will vary depending on how you interact with our App. In this section, we have set out the various purposes for which we use personal data collected through our App.
If you have questions about or need further information concerning the legal basis on which we collect and use your personal data, including how we balance our legitimate interests against your rights and freedoms where applicable, please contact us using the contact details provided under section 1 above.
1. To register you as a user of the App.
Where you register as a user of the App, we will ask you to provide basic personal information to set up your account and verify your account details via SMS.
Categories of personal data used for this purpose:
Our lawful basis for processing this personal data: It is necessary to perform a contract with you. If you do not provide this information, we will not be able to register you as an App user. Where you have chosen to provide the information listed above as 'optional', we process this on the basis of your consent – you can delete this information from the App at any time.
You can also choose to log in or register with the App via your account on a third party website (such as Facebook or Google). Where you choose to do this, you will be transferred to the third party website, where you can provide your account details and consent to relevant permissions. Where you do this, your third party account and your App account will be linked and we will receive some of your personal information from the third-party account.
Categories of personal data used for this purpose:
Our lawful basis for processing this personal data: We process this personal data on the basis of your consent. If you do not wish to link your App account with your Facebook or Google account, you can choose to instead create an account directly via the App. If you have logged into the App using a third party account in the past and wish to unlink your accounts, you can do so via the settings on the relevant third-party webpage.
2. To procure and manage journeysyou request through the App.
We will need to process information about you in order to arrange and manage the journeys that you order through the App (whether you travel by taxi, private hire vehicle, e-scooter, e-bike or another mode of transport).
This includes allowing you to interact with maps using Google Maps (which is integrated into the App) so that you can pin the pick-up and drop off locations for your journey on the map or (where you have chosen to activate GPS settings) to identify your location via GPS. We use Google Maps in order to calculate the anticipated cost of your journey and to interactively show you the distance to the vehicle which will be carrying out your journey.
Where you choose to hire an e-scooter, e-moped or rent a car (depending on legal requirements), we will need to verify your driver's licence. You will only be able to hire once the verification is complete. Verification is valid for 36 months, after which point we will ask you to re-verify before you carry out any more hires.
After you have procured a journey, your driver may phone you about your journey (for example, to inform you about delays or ask your to clarify the pick-up location) – however, we use a phone masking service that means the driver will not be able to see your phone number at any time.
Categories of personal data used for this purpose:
live location - if your turned on location sharing, we will also collect your live location from the moment you order a ride until it starts. You can change it at any time in the App settings,
Our lawful basis for processing this personal data: It is necessary to perform a contract with you (or to take steps at your request prior to entering into a contract). If you do not provide this information, we will not be able to procure the journey or hire that you request or allow you to interact with maps via the App.
Where you have chosen to provide the information listed as 'optional', we process this on the basis of your consent – you can delete this information from the App at any time.
Alternatively we process this personal data as it is necessary for our legitimate interest to ensure a high quality experience for you.
3. To respond to your enquiries and send you service-related communications.
You can contact FREE NOW in several ways, such as our online contact form (https://support.free-now.com/hc/requests/new), by letter or by phone (where possible). Whenever you get in touch with FREE NOW, we process your personal data so that we can manage and respond to your enquiry or comment. We will also contact you from time to time with service communications (e.g. to provide a receipt for a journey you have taken or to notify you of updates to our T&Cs).
Categories of personal data used for this purpose: Depending on how you choose to contact FREE NOW, we will process the following types of personal data:
Our lawful basis for processing this personal data: Where you contact us to enter into or enforce a contract between you and FREE NOW, our lawful basis will be that the processing is necessary to perform a contract with you and/or to take steps at your request prior to entering into a contract.
In all other cases, we process this personal data as it is necessary for our legitimate interest in responding to passenger enquiries and in managing our relationship with customers and potential customers. Where you contact FREE NOW by phone call, you will be notified that your phone conversation with FREE NOW is being recorded – however, you will be given the option to refuse to the recording at the start of your call. Call recordings will be automatically deleted after 90 days.
4. To take payment for your journey.
Where you pay for your journey directly via the App, we will process payment-related information about you. Alternatively, you can also choose to connect your App account with a travel expense tool (such as Cytric or Concur). This will automatically transfer your journey invoices to an external service provider, who will process them to provide you/your employer with a detailed overview of travel expenses.
Categories of personal data used for this purpose:
Our lawful basis for processing this personal data: Where you choose to connect your account with a travel expense tool, we process this personal data based on your consent. Your use of a travel expense tool is entirely voluntary and you can withdraw your consent at any time in the App menu.
In all other cases, we process this personal information on the basis that it is necessary to perform a contract with you.
5. To manage ratings of our drivers and passengers.
On the App, you can provide ratings of drivers and vehicles used to provide your journey: your rating will be aggregated with ratings from other passengers and used to display the driver's average rating on the App. FREE NOW will be able to view your rating (from one to five stars) as well as the specific journey to which the rating is associated. However, your specific rating will not be shown to the driver you have rated and your associated journey details and individual rating will not be shown publicly via the App.
In addition, your driver can provide a rating for you as a passenger (for instance, to provide positive feedback or to inform us of problems). FREE NOW will use these ratings to create an average passenger rating score for you. Only you will be able to view this in your FREE NOW passenger profile. Your rating will not be displayed to drivers during the procurement of any journeys and your rating will not be used as the basis for any journey procurement or other decision about you. We urge our drivers to choose the passenger rating on the basis of the politeness and behaviour of the passenger.
Categories of personal data used for this purpose:
Our lawful basis for processing this personal data: We process this data on the basis of our legitimate interest in further developing and improving the quality of our services.
6. To manage fraud prevention and non-payment risks.
When you create an account with the App, FREE NOW will evaluate the risk of non-payment and/or fraud for each new means of payment linked with your account and for each booked journey. We do this using either of the following two methods in order to make a decision about whether or not you will be able to access the "Pay By App" functionality:
If the outcome of our review is that you cannot use the Pay By App functionality then you will be notified of this by e-mail. You will still be able to use the App to procure journeys and pay by other means (such as cash). If you wish to contest a decision that you will not be offered Pay By App, please contact us via https://support.free-now.com/hc/requests/new. You will also be able to contest a decision that has been made by fully-automated means. One of our trained employees will then review and reconsider the decision, taking your viewpoint into account when doing so.
We also carry out fraud prevention checks for your journey by using your profile picture (where you have uploaded one) to identify you. The driver who carries out your journey will temporarily be shown your profile picture to check that it matches the passenger taking the journey.
In addition, we carry out checks of the activity on users of our App to prevent ad-related fraud activity.
Categories of personal data used for this purpose:
Our lawful basis for processing this personal data: We process this data on the basis of our legitimate interest in fraud prevention and reducing the risks of non-payment by our customers.
In order to protect you against overpaying for journeys, your driver's mobile phone will transmit GPS coordinates to us at intervals throughout your journey. This helps us to ensure that the driver does not intentionally prolong your journey in order to obtain a higher fee. This means that, if you think you may have paid too much for a journey, you can request that we share information about the route of your journey.
Categories of personal data used for this purpose:
Our lawful basis for processing this personal data: We process this data on the basis of your and our legitimate interests in protection against overpayment and fraud prevention.
7. To fix bugs and improve the functionality of the App.
In order to fix issues, improve App functionality, and adjust the App to suit the needs of our passengers, we carry out technical analysis of how users interact with our App. Where possible, we will anonymise the personal data we use in order to carry out this activity.
Categories of personal data used for this purpose:
Our lawful basis for processing this personal data: It is necessary for our legitimate interests in improving the functionality and features of our App.
8. To send you news and personalised offers (marketing).
Where we are permitted to do so, we will send you news and personalised offers relating to products and services offered by FREE NOW and/or our third-party partners that we think may be of interest to you. Depending on the settings you have enabled in your App, we will send these to you by e-mail, text or through in-app or push notifications. You can withdraw your consent to receiving these marketing messages at any time (see section 7 (Your privacy rights) to find out how you can object to marketing messages). You can also withdraw your consent to marketing communications via the “Data Protection Settings" of the FREE NOW passenger App (under your “Profile”), by turning off the toggle relating to “News and personalised offers”Categories of personal data used for this purpose:
Our lawful basis for processing this personal data: Where we are permitted to do so by law, we process this information on the basis that it is necessary for our legitimate interest in marketing our services and providing relevant information to our customers and potential customers that we think will be of interest to them.In all other cases, we process this information on the basis of your consent.
9. To analyse the success of our marketing campaigns and advertise our services online.
We place adverts for our services on third-party websites. We also evaluate and analyse the performance of our marketing campaigns and channels to understand how users become aware of our App, how they respond to specific ad campaigns and how they use the App. To do this, we collect and process certain information about the devices used by our users, their online behaviour and the content of websites they visit. The personal data we collect for this purpose are aggregated by our advertising partner and anonymised shortly after collection. Our service providers therefore cannot identify an individual from the personal data they receive.
Categories of personal data used for this purpose:
Our lawful basis for processing this personal data: It is necessary for the purpose of our legitimate interests in advertising our services and understanding the effectiveness of, and improving, our marketing campaigns.
10. To provide personalised ads.
We use ‘custom audience’ and ‘lookalike’ targeting provided by third parties so that we can display targeted advertisements about our services on third party websites and apps to a specific audience (e.g., depending on the characteristics of the audience). We do this so that ads can be tailored to the likely interests of the relevant individual.
Categories of personal data used for this purpose:
Our lawful basis for processing this personal data: The legal basis we rely on for this processing activity is that you have provided your consent.
You can also withdraw your consent to this via the “Data Protection Settings" of the FREE NOW passenger App (under your “Profile”), by turning off the toggle relating to “Personalized Advertising”. Alternatively, you can send us a message via https://support.free-now.com/hc/requests/new or to by letter to the address set out in section 1 of this Privacy Notice.
Where you withdraw your consent, this will not affect the lawfulness of any processing that we carried out prior to your withdrawal. We will implement your changes as soon as possible (due to technical reasons, this will be no later than 48 hours from the withdrawal).
You can turn off this use of your advertising identifier:
You can also reset your advertising identifier at any time in the device settings (iOS: “Reset Ad-ID”; Android: “Reset Advertising-ID”). Where you do this, a new identification number will be generated for your device, which will not be linked with the data collected for your previous advertising identifier.
You can also withdraw your consent to this via the “Data Protection Settings" of the FREE NOW passenger App (under your “Profile”), by turning off the toggle relating to “Personalized Advertising”. Alternatively, you can send us a message via https://support.free-now.com/hc/requests/new or to by letter to the address set out in section 1 of this Privacy Notice.
Where you withdraw your consent, this will not affect the lawfulness of any processing that we carried out prior to your withdrawal. We will implement your changes as soon as possible (due to technical reasons, this will be no later than 48 hours from the withdrawal).
11. Marketing to potential business customers.
FREE NOW collects information about potential business customer contacts from public sources (such as LinkedIn) so that we can send them marketing materials about our services where we think these may be relevant to their business.
Categories of personal data used for this purpose:
Our lawful basis for processing this personal data: It is necessary for the purpose of our legitimate interest in identifying potential B2B customers and advertising our services.
12. To conduct market research and surveys.
If you have agreed to receive market research and surveys from us (e.g. during registration of your account on the App or by activating the relevant toggle in the App's privacy settings), we will send these to you from time to time. The surveys we send you will be personalised to you. Depending on the settings you have enabled, we will send these to you by e-mail, text or through in-app or push notifications. We do this so we can understand how you use our App and how we can improve our services.
Categories of personal data used for this purpose:
Our lawful basis for processing this data: We process this personal data on the basis of your consent.If you have provided your consent to this activity and you subsequently do not wish to receive these messages you can easily withdraw your consent by de-activating the relevant toggle in your “Data Protection Settings" of the FREE NOW passenger App (under your “Profile”). See also section 7 (Your privacy rights) on other ways you can withdraw consent and how we will implement your withdrawal.
13. To run our loyalty, referral and partnership programs.
If you take part in one of FREE NOW's loyalty or referral programs or partnership schemes we will use your personal data as necessary to provide you with the relevant loyalty or partnership rewards and to confirm your participation in the program. The terms and conditions of the relevant program will be provided to you at the time you sign up to it. In particular, we run a referral scheme for business accounts, by offering rewards when the new referred customer signs up and takes a certain number of journeys. If you are a B2B passenger that is referred through this scheme, we will contact you to ask if you would like to sign up to our services, and we will collect and share information with the person who referred you about your sign-up activity and the number of journeys you take.
Categories of personal data used for this purpose:
Our lawful basis for processing this data: Where participation in the program involves users signing up to a contract, we process this personal data on the basis that it is necessary for the performance of a contract with you (or to take steps at your request prior to entering into such a contract).
Otherwise, we process this personal data on the basis that it is necessary for our legitimate interest in conducting the loyalty or partnership program. However, your participation in any loyalty or partnership program is voluntary and you can choose not to participate and/or end your participation in accordance with the terms of the relevant program.
Lastly, the legal basis we rely on for the B2B referral scheme is the consent of the referred passenger. You have a right to withdraw it at any time and please see section 7 (Your privacy rights) on how you can withdraw consent and how we will implement your withdrawal.
14. To handle accident reporting.
Unfortunately, accidents sometimes happen. If you or your driver is involved in an accident during a journey, we will use some of your personal information in order to carry out internal reporting, provide information to our insurers and other relevant third parties, and comply with our legal obligations.
Categories of personal data used for this purpose:
Our lawful basis for processing this data: It is necessary for the purpose of our legitimate interests in maintaining internal records about accidents that take place, notifying our mobility service providers of incidents in accordance with our contractual obligations, and processing insurance claims.
We will also process your personal information on the basis that it is necessary for compliance with a legal obligation to which we are subject, where this is the case.
In limited instances, we will process this information to protect the vital interests of you or someone else.
15. To comply with our legal obligations.
We may use your personal data to provide information to competent authorities where we are required to do so by applicable laws or regulations (e.g. to our transport licensing authority or insurers).
The types of personal data we share for this purpose will vary depending on the nature of the legal obligation. However, common categories of personal data used for this purpose are:
16. Links to third-party websites.
Where you access a third party's website – for example, by following a link to our Facebook page via our website – the provider of that website will be the controller of the personal data you provide on that site. For information about how they will handle your personal data, you should refer to the privacy notice on that website.
We share your data with the following categories of recipients.
You may exercise your rights under the GDPR in respect of and against each of the parties (either FREE NOW or our third-party service mobility provider). However, to speed up the response, we would kindly ask you to exercise your rights via https://support.free-now.com/hc/requests/new.
In some cases, your personal information is transferred to, and processed in, countries other than the country in which you are resident. These countries may have data protection laws that are different to the laws of your country.
Specifically, our group companies are located inside the UK/EEA and we store all our data with a cloud service provider within the EU or in IT infrastructures and systems (employee computers) at our sites within the EEA/UK. Our third-party service providers and partners operate around the world. We have selected our service providers carefully to check that they will protect the personal data we share with them and we have engaged them in writing.
Where we transfer your personal data outside the UK or EU/EEA, we have taken appropriate safeguards to require that your personal information will remain protected in accordance with this Privacy Notice. This includes:
For more information on the appropriate safeguards that we have implemented, you can contact us using the details provided in section 1. We do not sell any personal data to third parties.
https://support.free-now.com/hc/requests/new or a letter to the address mentioned under section 1 above.
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilms
Cheshire
SK9 5AF
Helpline number: 0303 123 1113
We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.
We have taken appropriate technical and organisational measures to keep your personal data secure (in particular to protect your personal data against unauthorised access by third parties, as well as accidental or intentional modification, loss or destruction). We review these measures periodically and change them in line with state of the art security processes.
The transfer of your personal data from your device (e.g. smartphone) to us is always encrypted. FREE NOW is PCI DSS (Payment Card Industry Data Security Standard) certified.
We retain personal information we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or it to comply with applicable legal, tax or accounting requirements). In particular:
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
We may modify this Privacy Notice from time to time in the future in accordance with applicable data protection laws and regulations or in response to changing technical or legal developments. When we update our Privacy Notice, we will take appropriate measures to inform you, consistent with the significance of the changes we make.
Last updated: November 2023
