Last Updated: 22nd January 2020
- Riders who make requests for and avail transportation; and
- Drivers who provide transportation.
This policy (together with our policies on ‘How we process your data’, ‘Cookies and other technologies’ and ‘To whom we transfer your data’) sets out:
- Information we collect about you
- How we use your information
- Our promotional updates and communications
- Who we give your information to
- Where we store your information
- Child safety
- Payment processing
- How we protect your information
- How long we keep your information
- Your rights
- Changes to this policy
- Contact us
Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
For the purposes of the data protection laws and directives applicable to the European Union, (the “Data Protection Law“), the data controllers are:
- ANI Technologies Private Limited, registered at Regent Insignia, #414, 3rd Floor, 4th Block, 17th Main, 100 Feet Road, Koramangala, Bangalore – 560 034, Karnataka, India; and
- Ola Netherlands B.V., Joop Geesinkweg 901, 1114AB Amsterdam-Duivendrecht.
Information we collect about you
We will collect and process the following personal data from you:
- Information you give us:
This is information about you that you give us directly when you interact with us. This includes your profile information, login details, and other details required to create your register with us.
This is information about you that you give us by filling in forms on the Site or App or by corresponding with us by phone, e-mail or otherwise. It includes information you provide when you register to use the Site or App, subscribe to our service, search for a product, place an order on the Site or App, participate in discussion boards or other social media functions on or via the Site or App, enter a competition, promotion or survey, submit a query, and when you report a problem with the Site or App.
The information you give us may include your name (including account username), address (including the city you live in), e-mail address and phone number, financial and credit card information, personal description (including age and gender), photograph, login and password details. It may also include certain personal details of your emergency contacts that you add to your account, and whether you have a connection with others whose personal data we may collect or hold, for example family members and friends. We may also access contacts stored on your device in order for you to add them to your favourites or emergency contacts. Please note that we do not import or sync your contact with the Site/App.
You may also choose to share details of your membership in any loyalty programs with which we are partnered, including the date and expiry details of the membership, membership number and points/rewards accrued. We may also collect information from you to undertake market research and studies, conduct data analysis, determine and customize product or service offerings, to improve the products or Services or to make any other benefits/products/ services available to you.
- Information we collect about you from your use of the Site and/or App:
We will automatically collect information from you each time you visit the Site and/or use our App. This includes technical information, information about your visit, and your location data.
- Technical information
- Information about your visit
- Location data
- Transactional data
We collect information about how you use our Services, such as the types of content you view or engage with; the features you use or click on; the actions you take; the people or accounts you interact with; the content you post on the Services (including using device features such as cameras, microphones, and text entered when using the Services) where applicable; using and have last used our Services; and the time, frequency and duration of your activities.
Technical information may include the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, browser type, referring / exit pages and URLs, number of clicks, domain names, landing pages, pages viewed and other such information.
Information about your visit may include the full Uniform Resource Locators (URL), clickstream to, through and from our Site (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call our customer service number or social media handle used to connect with our customer service team. It may also include reference numbers used when you book a service through the Site or the App, and details of what, how, when and where you have engaged in services which we provide or services procured or booked using our services. Where the Services allow you to call or text other users using the Services, the information may also include call and text information, including the date, time and duration of the calls and texts.
Location data – we collect information through the Site/App as to your real time location to provide location services where requested or agreed to by you in order to deliver content and services that are dependent on knowing where you are, such as allowing passengers to find drivers, allowing drivers to find passengers for pickup and allowing the App to calculate the fare applicable to your journeys. Please note that we only collect your live location on the Site/App if you specify in your setting that you would like us to “always collect” your location. If you have not specified this, we not collect your live location unless you are accessing the Site/App or availing our services. This information is collected in combination with an identifier associated with your device to enable us to recognise your mobile browser or device when you return to the Site/App. You may also feed in your location manually in the Site/App. You may turn off location access using your device or not provide us your location manually, however, please note that without the ability to collect your location we will not be able to provide you our services. For example, while riders may be able to manually enter their location information, they will not be able to use certain aspects of the Services such as sharing live locations with their emergency contacts, friends or family. However, please note that collection of location information is required for drivers. Location information is collected from every driver, even if the corresponding rider’s location sharing is turned off for that trip.
Device information i.e. the devices you use (mobile phones, computers, tablets, etc.) to access our services such as the hardware models, operation system information, hardware and software information and version, file names, language preferences, IP address cookie information, advertising identifiers, plugins, browser version, device settings, and mobile network information. We may also collect information about operations or actions performed on the device, such as mouse movements and whether a window is in the foreground or background. We may recognise your devices to provide you with personalised experiences and advertising across the services you use. Please see our policy on ‘Cookies and other technologies’ for more information on how we use device information.
We will also collect certain transactional information from you regarding your trips, including the amount or fare charged (including taxes), the date and time of the rides, details of referral codes or vouchers used, the distance travelled and route taken, ratings and compliments, and details where you have contacted the driver or rider or our customer care personnel (such as call recordings, feedback over the App or Site, text messages or email, or over any other medium in which we may collect customer care information such as your complaints and requests). This information in generated about you by your use of the Services. This information is required for our record maintenance purposes, and for financial, tax, administrative and audit purposes. We may also require this information to provide better customer support to you, to detect and mitigate instances of fraud, and for any R&D purposes. We will also contact you regarding changes to our terms of service or privacy policies.
We may enable you to communicate with drivers or riders through our App or Site, through which we will collect information regarding the communications made, requests or complaints filed, the contents of any text messages, calls, files, and other information that are disclosed by you through these communication media, and the data and time of the communications. We will not share any personal information of your or any other party through such communication media, unless you choose to do so voluntarily. We may also use this data for better customer support services, for analytics, feedback on our Services, or for safety purposes.
We may collect demographic data about you through surveys and feedbacks. You many opt to provide this information to us, and we will use this to provide better or new Services to you. We may also receive demographic data from our third party partners regarding you, which we may combine with the data you provide to us.
We will also collect information regarding complaints or requests you place with our Data Protection Officer, and may also receive details regarding such complaints or requests from third parties you may appoint or regulatory, judicial or administrative authorities.
Other than your locations and device information and transactional data, we do not link this automatically-collected data to personally identifiable information.
- Information we receive from other sources.
This is information we receive about you:
- if you use any of the other websites or apps we operate or the other services we provide.
- from third parties through whom you are able to access or register for the services (e.g. where you are able to log in with a Google or Facebook account).
- from third parties we work closely with.
- where you request for Services for or on behalf of other users, or where you enable other users to request or receive Services for or on your behalf.
- our identified third-party business partners through which you may create an account with such third party or with us, access or use our Services through this third party’s services, or avail of certain benefits, discounts or referral promotions for our Services through the third party’s services. We may integrate our APIs or access such third party’s APIs to facilitate the transfer of such data.
- our vendors for certain services including background verification service providers, payment service providers, social media services, insurance services, and vehicle-related services.
- publicly available sources and marketing service providers the we engage.
Depending on the nature of your dealings with us or the services which we provide to you or which you may obtain or make available to others using our services, we may collect other types of personal data from third parties, including:
- where you are involved in providing transport-related services, identification, taxation, government or regulatory identifier (such as drivers’ licence details), and vehicle and insurance details;
- personal data relating to any complaints you make or are made about you, including recording of any calls in that regard;
- personal data collected and held via financial or payment systems about the payment mechanism or method that you might use (including credit card details) and the payments you may make for our services or any services procured or booked using our services;
- personal data collected by third-party marketing, survey and advertising service providers;
- personal data provided to any partners through which you create or access your account for the services, such as employee information provided to companies engaging in our corporate or other services, payment providers, social media services, on-demand media or services integrated with our services, or other websites (such as search engines) with which our services have been integrated;
- personal data which is accessible from your use of online sites or applications in which we have an interest or provide (such as messages for the purposes of issuing and receiving one time passwords and other device verification) and device-related or device-generated personal data. The latter might include your device details, device IDs, your location, network connections, network access and communication and session data. Location data may also be collected or derived from IP addresses, mobile numbers and network information.
You generally have the option of not identifying yourself or of using a pseudonym when dealing with us, but not where this is impractical (for example when you transact online with us or you apply to provide transport-related services) or where the law or a court order provides otherwise.
In this case we will have informed you when we collected that data if we intend to share your data internally and combine it with data collected on this site. We will also have told you for what purpose we will share and combine your data.
We are working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, and search information providers). We will notify you when we receive information about you from them and the purposes for which we intend to use that information.
We may use the aforementioned data as-is or in combination with other data that you provide us or is derived about you.
How we use your information
You can see a full list of the types of data we process, the purpose for which we process it, and the lawful basis on which it is processed here.
Please note that we use the information you provide to us for automated decision making and profiling in order to effectively provide you our services.
We use information held about you in the following ways:
- Information you give to us:
We will use this information to:
- Take steps in order to enter into any contract or carry out our obligations arising from any contract entered into between you and us including:
- administering your account with us;
- accessing and using our Services.
- verifying and carrying out financial transactions in relation to payments you make through the Site and/or the App;
- notifying you about changes to our service.
- Provide you with information about our goods or services we feel may interest you, in our legitimate interests provided these interests do not override your right to object to such communications. See ‘Our promotional updates and communications‘ below.
- Ensure in our legitimate interests that:
- content from our Site is presented in the most effective manner for you and for your devices.
- we provide you with the information, products and services that you request from us.
- Information we collect about you from your use of the Services
We will use this information in our legitimate interests, where we have considered these are not overridden by your rights:
- To administer the Services and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes.
- To keep the Services safe and secure.
- For measuring or understanding the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you.
- To improve the Services to ensure that content is presented in the most effective manner for you and for your computer.
- To allow you to participate in interactive features of our service, when you choose to do so.
- Information we receive from other sources
We will combine this information with information you give to us and information we collect about you in our legitimate interests (where we have considered that these are not overridden by your rights). We will use this information and the combined information for the purposes set out above (depending on the types of information we receive).
Our promotional updates and communications
We will share promotional updates and communications with your consent or, where applicable, in our legitimate interest. Where permitted in our legitimate interest, we will use your personal information for marketing analysis and to provide you with promotional updates and communications by email, telephone, text messages, in-application messages and/or push messages about our products and/or services. We may also share information with third-party social media and other partner platforms in order to provide you with promotional update communications. You may view our partner platforms here.
The types of communications we may sent includes information regarding Ola’s services, features, research and development efforts, surveys, studies, news, updates, and events. We may also personalise the communications we send based on your use of the App/ Website, such as your frequently visited locations to provide you with offers, your existing user preferences and settings, and feedback you may have provided to us.
You can object to further marketing at any time in your profile settings or by selecting the “unsubscribe” link at the end of our marketing and promotional update communications to you.
Who we give your information to
We may give your information to:
- Any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, who support our processing of personal data under this policy. Our group entities include the data controllers identified in this Policy.
- Organisations who process your personal data on our behalf and in accordance with our instructions and the Data Protection Law. This includes in supporting the services we offer through the Site and/or the App in particular those providing website and data hosting services, providing fulfilment services, distributing any communications we send, supporting or updating marketing lists, facilitating feedback on our services and providing IT support services from time to time. These organisations (which may include third party suppliers, agents, sub-contractors and/or other companies in our group) will only use your information to the extent necessary to perform their support functions.
- Advertisers and advertising networks that require the data to select and serve relevant adverts to you and others. We do not disclose information about identifiable individuals to our advertisers, but we will provide them with aggregate information about our users (for example, we may inform them that 500 men aged under 30 have clicked on their advertisement on any given day). We may also use such aggregate information to help advertisers reach the kind of audience they want to target. We may make use of the personal data we have collected from you to enable us to comply with our advertisers’ wishes by displaying their advertisement to that target audience and subject to the cookie section of this policy. We will not send any third-party advertisements without your consent.
- Analytics and search engine providers that assist us in the improvement and optimisation of our site and subject to the cookie section of this policy (this will not identify you as an individual).
- Business partners or identified co-branding or co-marketing partners who provide services to you via the Site or the App or via their own applications and services, and with whom we have entered into agreements in relation to the processing of your personal data.
- Parties necessary for the provision of services to you and with whom we have entered into agreements in relation to the provision of services. For example, if you have requested to use the service as a customer or a driver-partner, we will share only such personal information to facilitate and complete the service. We do not provide your contact details in such cases.
- Payment processing providers who provide secure payment processing services. Your payment card details are not shared with us by the provider.
- You can find more details regarding transfer of your information here.
Where we store your information
We may transfer your personal information outside the EEA:
- In order to store it.
- In order to enable us to provide services to you and fulfil our contract with you. This includes delivery of services that you have purchased (for example, if you are registered for the service in a country in the EEA but are using the App to book a service outside the EEA), processing of payment details, and the provision of support services.
- where we are legally required to do so.
- in order to facilitate the operation of our group of businesses, where it is in our legitimate interests and we have concluded these are not overridden by your rights.
We may transfer your personal information to the following countries outside the EEA such as India, Singapore, Indonesia, Ireland, the Philippines and the United States of America.
The Website/App is intended for use only by persons who are at least 18 years of age. By using the Website/App, you confirm to us that you meet this requirement.
How we protect your information
All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted using SSL technology. Where we have given you (or where you have chosen) a password which enables you to access certain parts of the Services, 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 the services; 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.
Our Site may, from time to time, contain links to external sites. We are not responsible for the privacy policies or the content of such sites.
How long we keep your information
We retain personal data for (i) as long as you have an account with us in order to meet our contractual obligations to you, and (ii) for six years after that to identify any issues and resolve any legal proceedings. We may retain information for any other legal or regulatory requirement. During the period of retention, whether or not you use the App/ Website or access the Services, we may use your information for purposes of taxation, litigation or resolution of any claims, insurance, safety and security, fraud management or internal research. We may also retain aggregate or anonymised information beyond this time for research purposes and to help us develop and improve our services. You cannot be identified from aggregate or anonymised information retained or used for these purposes.
Subject to applicable law, you have the right under certain circumstances:
- to be provided with a copy of your personal data held by us. Such right of access can normally be exercised free of charge, however we reserve the right to charge an appropriate administrative fee, for instance where you request multiple copies of your personal data;
- to request the rectification or erasure of your personal data held by us;
- to request that we restrict the processing of your personal data (while we verify or investigate your concerns with this information, for example);
- to object to the further processing of your personal data, including the right to object to marketing (as mentioned in the section ‘Our promotional updates and communications above);
- to request that your provided personal data be moved to a third party.
You may opt out at any time from allowing further access by us to your location in your device settings. You can also stop all information collection by un-installing the App. You may use the standard un-install processes as may be available for your mobile device.
Your right to withdraw consent: Where the processing of your personal information by us is based on consent, you have the right to withdraw that consent without detriment at any time by contacting us on the details provided below. You can also change your marketing preferences at any time as described in the section ‘Our promotional updates and communications‘ above. Please note that withdrawing of consent has no impact on earlier processing of your personal data on such basis and does not prevent us from invoking another available legal basis for the processing of such personal data.
Right to lodge a complaint: If your request or concern is not satisfactorily resolved by us, you may approach your local data protection authority. The ‘Information Commissioner’ is the supervisory authority in the UK and can provide further information about your rights and our obligations in relation to your personal data, as well as deal with any complaints that you have about our processing of your personal data.
Riders may use the self-serve function on the Website/App in order to exercise the above rights. Drivers may exercise these rights by contacting us at email@example.com. We may reach out to you to verify your identity or fulfil any other verification requirements before processing a request.
Please note that we may be unable to delete your information if there is a pending claim or dispute relating to your account, including any outstanding payments.
Changes to this policy
This policy was last updated on 21 January 2020.
Ola Netherlands B.V.
Joop Geesinkweg 901, 1114AB Amsterdam-Duivendrecht
Email address: firstname.lastname@example.org
Ola UK Private Limited
Suite 139, Business Design Centre, 52 Upper Street, London, N1 0QH
Email address: email@example.com