Effective Date: January 2023
This Privacy Notice explains how Fastride Networks and/or its Affiliates (collectively “Fastride”, “we” or “us”) collects and uses Personal Data. The Notice applies to all users of Fastride’s mobile applications, websites, call-centre or technology (collectively, the “Fastride Platform”), users of any other products and services we provide, and when users interact or communicate with us (all collectively, the “Services”). Our Privacy practices relating to Users in the United Arab Emirates and Pakistan, Guest Users and Visitors are detailed in Sections 11 to 14.
By accessing or using the Services, you confirm that you have read this Privacy Notice in full and understand that information collected by Fastride in accordance with this Privacy Notice may be used in accordance with Applicable Laws, this Privacy Notice and our End User or Captain Terms of Use.
Unless stated otherwise, Fastride Network is the data controller for the Personal Data collected in connection with the use of Fastride’s Services.
1. Scope and Application
2. Collection of Information
3. Use of Personal Data
4. Sharing of Personal Data
5. Automated decision taking
6. International Transfer of Personal Data
7. Storage of Personal Data
8. Your Choices
9. Security Precautions
10. Cookies
11. Special Notice to Hala users in the United Arab Emirates
12. Guest Users
13. Suppliers
14. Visitors
15. Changes to this Privacy Notice
16. Contact Us
1. Scope and Application
This Privacy Notice applies to all individuals anywhere in the world who access or use our Services. It specifically applies to:
(each referred to in this Privacy Notice as “you” or "Data Subject"as the context requires).
Across this Notice, we will be using some important definitions:
Personal Data is any data or information that relates to an individual and which could, of itself or in combination with other data or information, identify who an individual is.
Products are any goods or services displayed on the Fastride Platform.
Merchant Partner is a third party that makes available the delivery of goods, restaurant meals or services through the Fastride Platform.
Process or Processing means the collection, storage, use or transfer of
Personal Data.
Terms of Use means the Customer or Captain Terms of Use.
2. Collection of Information
Depending on the Services you are accessing or using, we collect and use:
Information that you provide directly to us;
Information about the use of your account and our Services;
Information obtained from other sources and third parties, which may include information about you.
A. Information You Provide to Us
Whether you are an End User or a Captain, you are solely responsible for the accuracy of the information you provide, and Fastride will only modify or update your Personal Data upon your request or when you modify your account details.
End Users If you are an End User, we collect Personal Data that you provide directly to us
through your access or use of the Services, such as when you:
create or modify your account for use of any of our Services;
access the Fastride Platform;
request Services on your behalf or on behalf of others;
contact Fastride's customer support;
complete user surveys or provide feedback; or
otherwise communicate with us.
The Personal Data collected in these processes may include your:
name;
email address, from which we can also deduce your place of employment when sharing an enterprise/corporate email address;
phone number;
addresses that you ask Fastride to store in your profile for future reference;
payment method;
residential address;
payment information, including your preferred payment method, on condition that Fastride uses a third-party PCI-compliant vendor to process and store credit and debit card information;
images/video, including photos or videos submitted to verify your identity such as through facial verification technologies;
identification card (copy) and the information included on it, including but not limited to your gender, date of birth, nationality, profession and/or image; and
other information which we reasonably require or that you choose to provide.
Personal Data of children under 18 years of age
Fastride does not knowingly collect, keep or maintain Personal Data from children, as the Fastride Platform may only be used by persons older than 18 Gregorian years and individuals who can form legally binding contracts under applicable law.
If you book a ride or use another of our Services on behalf of a child under the age of 18 Gregorian years then we might indirectly collect information about that child. Each time you are booking a ride or using another of our Services on behalf of a child under the age of 18 Gregorian years you represent and warrant
to us that:
you have the legal right to do so on behalf of the child;
you have the legal right to provide consent on the child's behalf to the collection and use of that child's Personal Data by us; and
you provide that consent to us by continuing to book the ride or using our Services on behalf of the child to the fullest extent possible under the
applicable laws.
Captains If you are a Captain we collect Personal Data you provide directly to us through
your access or use of the Services, such as when you:
request to create or modify your account for use of any of our Services as a Captain;
attend a Fastride or third party premises to onboard as a Captain;
access the Fastride Platform;
contact Fastride's customer support;
complete user surveys or provide feedback; or
otherwise communicate with us.
The Personal Data collected in these processes may include your:
name;
email address;
phone number;
postal address;
date of birth;
gender;
images/video, including photos or videos submitted to verify your identity such as through facial verification technologies;
identification card (copy) and the information included on it;
residency card (copy) and the information included on it;
driving licence (copy) and the information included on it;
reference letter;
payment information, including your preferred payment method and bank account details, on condition that Fastride uses a third-party PCI- compliant vendor to process and store credit and debit card information;
self-contractor registration documentation (copy);
insurance documentation (copy) and the information included on it;
tourism licence (copy) (if required under Applicable Laws) and the information included on it;
taxi licence or public transport driver permit (copy) (if required under Applicable Laws);
proof of non-conviction record (if required under Applicable Laws);
evidence of health or fitness to provide services (if required under Applicable Laws); and
other information which we reasonably require or that you choose to
provide.
When we collect sufficient Personal Data from you in order to open an account for you, we will generate an account number known as your “Fastride Account ID”. The Fastride Account ID is unique to you and is used by us to identify you across our various Services and geographies.
Please note that if you choose not to provide us with some of this Personal Data, or request that we erase some or all of it, we may not be able to provide you with our Services at all, or provide it to the same standard we can if we are using that Personal Data.
B. Information We Collect Through use of Our Services
End Users and Captains
When you access or use our Services, either as an End User or Captain, we collect information, some of which will constitute Personal Data. In some cases, we collect this data through cookies, pixels, tags, and similar tracking technologies that create and
maintain unique identifiers. Such information may include your:
details of the specific Service you have requested;
specific requirements in respect of an order you make via our Services;
Captain feedback you choose to provide;
your specific location at the time you are accessing or using our Services;
the time and date of your booking of the Service, either at that time or at a time in the future;
your booked or actual destination;
your trip route;
the third party supplier you have used, for example which Merchant Partner you have placed an order from; and
the Personal Data of individuals on whose behalf you access or use our Services, for example, when you book a ride for others or request the delivery of a Product to or from a friend.
If you are a Captain we also collect:
any End User feedback you choose to provide;
details of any journeys you have made or services you have provided;
your trip route;
the time and date of any bookings you accepted, rejected or cancelled.
We also use GPS technology to determine your current location. For Captains, GPS technology may be used when the Fastride application is running in the background and foreground, whether the Captain is online or offline. For End Users, GPS technology will only be used when the Fastride application is active in the foreground of your phone’s applications or during a Trip.
Some of our location-enabled Services require your Personal Data for the feature to work. By accepting the terms of this Privacy Notice you are agreeing to the use of GPS technology when relevant to the use of our Services. Use of GPS is a setting that you can switch on and off from your phone device settings at any time.
C. Information We Collect From Other Sources
End Users and Captains
We may also receive information, including Personal Data, from other sources and
combine that either with Personal Data we receive from you or collect through our Services. For example:
If you are an End User we may also:
collect information about you from your employer, if your employer uses one of our enterprise solutions; and
receive ratings by Captains after they have provided services to you.
If you are a Captain we may also:
receive ratings by End Users after you have provided services to them;
if you also interact with our Services in another capacity, for instance if you are both an End User and a Captain or if you make use services by one or more of our Affiliates, we may combine or associate that information;
receive information relating to you from a third party company with which we contract, if you are a Captain that is employed by or contracted with a third party
company;
receive information from your insurance, vehicle, or financial services providers;
obtain any additional information on you, as required, from publicly available sources or governmental authorities.
3. Use of Personal Data
End Users and Captains
We may use Personal Data collected in the manners described above to:
Provide, maintain, and improve our Services
Perform internal administration and operations, including to conduct data analysis, testing, and research; to monitor and analyze usage and activity trends; and to troubleshoot software bugs and operational problems
Send or facilitate communications (i) between End Users and Captains, such as estimated times of arrival (ETAs), or (ii) at your direction, between you and a contact of yours in connection with your use of certain features, such as referrals or invites;
Send you communications to you, including administrative or Service-related messages, receipts and other communications we think will be of interest to you, including information about existing and/or new products, services, promotions, news, and events of Fastride and other companies, where permissible and according to Applicable Laws;
Process contest, sweepstake, or other promotion entries and fulfill any related awards;
Allow you to participate in interactive features of our Services;
Keep our Services safe and secure, including screening Captains and End Users before enabling their use of our Services and at subsequent intervals, including
Captains only
We may use Personal Data collected in the manners described above to:
In certain regions, using information derived from the Captain’s license photos, and other photos submitted to Fastride, for safety and security purposes. This includes a real-time ID feature, which prompts you to share a selfie before going online or while online to help ensure that the individual using our app matches the Captain account we have on file. This also includes comparing photographs that we have on file against photographs (i) of other users to prevent identity- borrowing, and (ii) from public databases to verify user identity; and
Offer, obtain, provide, or facilitate insurance, vehicle, invoicing or financing
solutions.
4. Sharing of Personal Data
Depending upon the purposes for which we have collected your Personal Data, we may share your Personal Data:
End Users and Captains
We may share your Personal Data:
With Fastride Affiliates;
With third parties that we use to carry out work on our behalf or to perform a contract we enter into with them, including:
Google, in connection with the use of Google Maps in Fastride Platform (see Google's privacy policy for information on their collection and use of data).
social media companies, including Facebook, in connection with Fastride's use of their tools in the Fastride Platform (see Facebook's privacy policy for information on their collection and use of data);
vendors who help us verify identity, background information, or who screen users in connection with sanctions, anti-money laundering, fraud or know-your-customer requirements. In some cases, these service providers may retain identity documents that are suspected to be fraudulent for the purpose of identifying fraud in the future;
cloud storage providers;
payment processors and facilitators;
marketing partners and marketing platform providers, including social media advertising services, advertising networks, third-party data
providers, and other service providers that help us understand you better as a user and measure advertising effectiveness;
research partners, including those performing surveys or research projects in partnership with Fastride or on Fastride's behalf;
vendors that assist Fastride to enhance the safety and security of our Services;
consultants, lawyers, accountants, and other professional service providers;
airports, including when required by airport authorities as a condition of operating on airport property;
telecommunications companies, utility providers and other third parties to offer to you and enable you to buy prepaid services or pay for postpaid services you obtain from them;
e-Commerce providers to enable to you to purchase goods and services from them through Fastride PAY.
financing partners; and
financial institutions, such as banks we partner with to offer joint products.
With third parties where you choose to pay bills as part of our Fastride Pay services;
With financial institutions that we have partnered with to provide the Fastride Pay service;
With third parties to market their products or services to you if you have agreed to receive promotional updates;
If we otherwise notify you and you consent to the sharing;
With third parties in an aggregated and/or anonymized form which cannot reasonably be used to identify you;
With law enforcement officials, financial regulators, anti money laundering agencies, government authorities, public health officials, competent authorities or other third parties: (i) to enforce or apply our Terms of Use; (ii) to investigate potential breaches of these terms or applicable laws or if we believe your actions are inconsistent with our Terms of Use; (iii) to protect the rights, property, or safety of Fastride or others; or (iv) if we believe disclosure is in accordance with, or is otherwise required by any applicable law, regulation, operating license or agreement, legal process or governmental requests, or where the disclosure is otherwise appropriate due to safety or similar concern;
With a claims processor or an insurer to provide any necessary information (including your contact information) if there is a complaint, dispute or conflict, which may include an accident, involving you and another party and such information or data is necessary to resolve the complaint, dispute or conflict; and
With third parties in connection with, or during negotiations of, any merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or into another company.
End Users only
We may share your Personal Data:
At your request, such as when you agree to share your ETA and location with a friend;
With Captains, to enable them to provide the Services you request. For example, we share your name and pickup and/or drop-off locations with Captains;
With Merchant Partners and/or their point-of-sale providers for order fulfillment, delivery, communications and marketing purposes. In some cases, including when the Merchant Partner is self-delivering the Order to you, we will provide your information to that Merchant Partner in a similar manner as if you had placed the order for Services directly with the Merchant Partner;
With third parties to provide you with a service you requested, including bill payment services and services that you may have requested through a partnership or promotional offering made by a third party or us;
With third parties with whom you choose to let us share your Personal Data, including other applications or websites that integrate with our API or Services, or those with an API or service with which we integrate;
With Hala in the manner identified in this Privacy Notice; or
With your employer (or similar entity) if your employer participates in any of our enterprise/corporate solutions.
Captains only
With End Users, to enable them to identify you and your vehicle;
With any Merchant which you are collecting an order on behalf of an End User;
With your employer or the third-party transportation company your Captain account is associated with; and
With insurance companies or providers of fleet financing solutions whose product
offerings we consider may be of interest to you.
5. Automated decision taking
We use personal data to make automated decisions relating to use of our Services, such as to:
Determine Captains and End Users ratings, and deactivating where there are low ratings;
Match available Captains to End Users requesting services based on availability, proximity, and other factors;
Enable dynamic pricing, in which the price of a ride or the delivery fee is determined based on constantly varying factors such as the estimated time and distance, the predicted route, estimated traffic, and the number of Captains and End Users using Fastride at a given moment; and
Flag Captains and/or End Users who are identified as having engaged in fraud,
unsafe activity, or other activities that may harm Fastride and/or others.
take appropriate measures to protect your Personal Data in accordance with this Privacy Notice and the laws of the country from where the transfer is occurring.
Where Applicable Laws require you to consent to the processing of personal data outside the country where you access the Fastride Platform, you provide that consent to us by continuing to book the ride or using our Services to the fullest extent possible under the Applicable Laws.
Storage of Personal Data
We will store and retain your Personal Data for the period of time necessary for the purpose for which the data has been collected, unless the nature of the purpose changes in which case the retention period may be extended or shortened.
Apart from the purposes for which we collect your Personal Data, we also store and retain this Personal Data to preserve the integrity of our databases, to carry out on- going Services on your behalf, for research, analytics and statistics purposes and to ensure compliance with applicable laws and regulations.
Following an account deletion request (where warranted in accordance with the data subject rights referred to below), we will erase or archive from active use the Personal Data of the individual to which the requirement or request relates, unless we are required to retain it due to legal or regulatory requirements, for purposes of safety, security, and fraud prevention, or because of an issue relating to your account such as an outstanding credit or an unresolved claim or dispute.
Your Choices
1. Device permissions
Most mobile device platforms (iOS, Android, etc.) have defined certain types of device data that apps cannot access without the device owner’s permission. Different platforms have different methods for how that permission can be obtained. Please check the available settings on your device or check with your provider.
2. Marketing and Opting Out
In some countries we cannot provide you with any direct marketing communications unless we have obtained your express consent to do so in advance.
In all cases, Fastride provides End Users and Captains the opportunity to opt-out of receiving direct marketing communications from us and our partners:
in any direct email marketing communication that you receive from us; and
for End Users, from the ‘Settings’ menu in the Fastride application.
3. Data Subject Rights
If you would like Fastride to correct personal data Fastride holds about you, please read here. This enables you to have any incomplete or inaccurate information Fastride holds about you corrected.
If you decide to delete your account, follow the steps mentioned here. Please note that if you are a Captain, additional steps may be required to give effect to this request.
Depending upon which country you are in at the time that we collect and use your Personal Data and the Service that you make use of you may have some or all of the following rights under applicable law:
To request access to your data, including your profile data and trip or order history (commonly known as a "data subject access request"). If the information you request reveals personal data about a third party, we will: (i) seek that individual's consent before responding to your request, (ii) consider if it is otherwise reasonable to provide it to you; or (iii) we will redact third parties' personal data before responding. If we are unable to provide you with access to your personal data because disclosure would infringe the rights and freedoms of third parties, we will notify you of this decision.
To request erasure of your Personal Data. This enables you to ask Fastride to
erase Personal Data where:
your Personal Data is no longer needed for the purposes for which it was collected;
the sole legal ground for processing was your consent and you have withdrawn it;
you have objected to processing of your Personal Data on the legal grounds relating to your particular situation, and Fastride cannot prove that there are overriding legitimate interests for processing;
your Personal Data were processed unlawfully; or
your Personal Data must be erased in order to comply with legal requirements.
Before requesting to delete an account, you are required to complete/cancel and active or schedule orders or bookings, cancel any Fastride Plus or Bike subscriptions and empty your Fastride PAY wallet. If you are the end user of an enterprise/corporate account, we may be unable to process your deletion request if there are outstanding
payments for that enterprise account.
After we receive your erasure request, you will be logged out of your Fastride account. We will process your request within 90 days. If you log in your Fastride Account during these 90 days, your deletion account will be cancelled and your account will remain unchanged.
Fastride may be required to retain some data in line with legal or regulatory requirements, for purposes of safety, security, and fraud prevention, or because of an issue relating to your account such as an outstanding credit or an unresolved claim or
dispute.
To object to us processing of your Personal Data where Fastride is relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground.
To request us to restrict our processing of your Personal Data where:
you consider that our processing of your Personal Data is inaccurate;
you consider that the processing is unlawful and you oppose the erasure of your Personal Data and you require the restriction of the processing instead;
we no longer need the Personal Data for the purposes of the processing but the Personal Data is required by you for the establishment, exercise or defence of a legal claim; or
where you require verification that processing on the legitimate interests of
Fastride override your interests.
To revoke your consent, where we have expressly asked for your consent as a legal basis to process your Personal Data. The revocation of your consent will not affect the lawfulness of the processing based on your prior consent.
Depending on your location or the version of the Fastride application that you are using, you may exercise these rights through the Settings menu in the Fastride app or by contacting us here.
We will contact you for additional information if we are unable to verify your identity, the scope of your request is unclear or does not provide sufficient information for us to conduct a search (for example, this will be the case if you request “all information about me”). Once we have all the information, we need to locate your personal data, we will begin processing your request.
Applicable law may allow or require us to refuse to act on your request, or we may have destroyed, erased, or made your personal data anonymous in accordance with our record retention obligations and practices. If we determine that your request does not have a legal basis, we reserve the right to not further process your request and we will inform you of this decision.
In addition, depending on your location, you may have the right to file a complaint relating to our handling of your Personal Data with the data protection authority in your country.
Security Precautions
Your Fastride profile is password-protected so that only you and authorized Fastride
“Authorised Personnel”
employees or service providers ( ) have access to your
account information. Fastride’s Authorised Personnel will never proactively reach out to you and ask for any personal account information, including your password.
Fastride makes every effort to ensure that your Personal Data is secure on its systems. Fastride has colleagues dedicated to maintaining adherence to this Privacy Notice and
other privacy initiatives, periodically reviewing security of our Services and making sure that all Fastride colleagues are aware of our security practices. Unfortunately, no data transmission over the Internet can be guaranteed to be 100% secure. As a result, Fastride cannot guarantee the security of any Personal Data you transmit to us, and you do so at your own risk. If you have any further questions on this issue, refer to the Terms of Use. To the extent permitted by Applicable Law, Fastride expressly disclaims any liability, and you hereby waive any claims, and indemnify us for any claims that may be brought by third parties who access or use our Services via your account, that may arise should any other individuals obtain the Personal Data Fastride collects about you or third parties who access or use our Services via your account.
Cookies
distinguishing you from other users of on the Fastride Platform;
remembering your preferences and settings
understanding the online behaviors and interests of people who interact with our Services, including determining the popularity of content and analysing site traffic and trends
improving our Fastride Platform and the Services we provide
Cookies are small text files that are stored on browsers or devices by websites, apps, online media, and advertisements. We use cookies and similar technologies for purposes such as:
beacons, SDKs, and other technologies to identify the devices used by visitors to our websites, as well as when they visit other online sites and services.
11. Special Notice to users in the United Arab Emirates and Pakistan
If you are accessing or using services provided by Fastride in the UAE and Pakistan, this section applies to you. This section should be read in conjunction with the Term of
Use and Privacy Policy.
Fastride has been engaged by Hala to provide certain technology and Processing services in support of business within the UAE and Pakistan. As a result, Fastride may be required to Process your Personal Data on behalf and to enable you to access or use the products or services provided by Company.
To the extent that you are using services, then any Personal Data that you provide through the Fastride Platform will be Processed by Fastride for the purposes of providing its service to you. When using services you are also agreeing to this Processing of Personal Data by Fastride on behalf of these purposes, and to the transfer of any Personal Data about you that Fastride Processes for these purposes. When this occurs Fastride is deemed responsible for determining the purpose and means of that Processing. To the fullest extent permitted under Applicable Laws Fastride shall have no liability under or in connection with the processing of Personal Data in connection with Fastride’s provision of services to Company.
Note that the Processing referred to in this section 10 is separate from any Processing conducted by Fastride for the purposes of providing you with Fastride Services via the
Fastride Platform, including via the Fastride Super App.
Marketing
You consent that both Fastride and Hala may use the Personal Data you provide via the Fastride Platform for the purposes of either Fastride directly contacting you to market their separate services to you.
12. Guest Users
We consider you a Guest User if you receive trips or deliveries but are not the owner of an account with Fastride, such as when:
You purchase physical products from third parties (including restaurants, ecommerce platforms or other merchants) that use the Fastride Platform for the delivery of the physical products to you.
You request a trip or delivery via partner websites or apps such as ride-hailing aggregators.
Your location is marked as a pickup or drop off location for our Order Anything services.
A trip or delivery is arranged by another account owner.
When a Fastride User transfers money to you.
Guest User personal data may be associated with, and accessible by, the owner of the Fastride account.
In these cases, your personal data is used and may be shared with third parties: (i) to provide such trips, deliveries or to enable such transfers; and (ii) for purposes of safety and security, customer support, research and development, enabling communication
between users, and in connection with legal proceedings and requirements.
13. Suppliers
We consider you as a Supplier if you are an individual (not Captains) that provide services to Fastride, either in their own capacity, or on behalf of an organization as a member or employee of that organization.
If you are a Supplier or work for a Supplier, we collect Personal Data when you, or the business you represent provides, or seeks to provide us with, services; or otherwise communicate with us.
The Personal Data collected during may include:
your name;
your email address;
your phone number;
your postal address;
passport or national identification number;
bank information where payment for Services will be made;
information on shareholders, principal officers, financial history, references, and ultimate beneficial owners; and
other information which we reasonably require or that you choose to provide.
We may use Personal Data collected in the manners described above to:
To contact you with regards to the provision of your services to us; and
To facilitate payments to you; and
To consider our potential or current relationship with your business.
If you are a Supplier we will be relying on third parties who help us verify identity and background information for legal, regulatory, anti-money laundering, sanctions and security purposes. This can include screening against sanctions lists, lists of politically exposed persons and relatives/close associates of such persons, and adverse media.
Please note that if you choose not to provide us with some of this Personal Data, or request that we erase some or all of it, we may not be able to engage you or continue to engage you to provide services to us.
Visitors
We consider you as a Visitor if you visit Fastride premises other than as a Fastride employee or individual contractor. When visiting Fastride premises, you may be asked to input personal information and register as a visitor using a visitor management system. During this registration, you may be also asked to sign a non-disclosure agreement.
This information is used to ensure the safety of individuals within Fastride premises and to safeguard information that is shared with you during your visit at Fastride premises.
Changes to this Privacy Notice
We may change this Privacy Notice from time to time. If we make significant changes in the way we treat your Personal Data, or to the Privacy Notice, we will provide you notice through the Services or by some other means, such as email or a push notification.
To the extent permitted by Applicable Law, your continued use of the Services after such notice constitutes your consent to the changes to the extent permitted by law.
We encourage you to periodically review this Privacy Notice for the latest information on our privacy practices.
16. Contact Us
If you have any questions, comments and requests related to this Privacy Notice, or if you have any questions about how Fastride processes your Personal Data, please