Roa Driver Privacy Policy

I. Introduction

When you use Roa driver, you trust us with your personal data. We’re committed to keeping that trust. That starts with helping you understand our privacy practices.

This notice describes the personal data we collect, how it’s used and shared, and your choices regarding this data. We recommend that you read this along with our privacy overview, which highlights key points about our privacy practices.

Last modified: October 21, 2020

Effective date: October 21, 2020

II. Overview

A. Scope

This notice applies to users of Roa driver’s services anywhere in the world, including users of Roa driver’s apps, websites, features, or other services.

This notice describes how Roa driver and its affiliates collect and use personal data. This notice applies to all users of our apps, websites, features, or other services anywhere in the world. This notice specifically applies to:

• Riders: individuals who request or receive transportation, including those who receive transportation requested by another individual

• Drivers: individuals who provide transportation individually or through partner transportation companies

• Delivery recipients: individuals who request or receive food, or other products and services

• Delivery partners: individuals who provide delivery or other services

This notice also governs Roa driver’s other collections of personal data in connection with Roa driver’s services. For example, we may collect the contact information of individuals who use accounts owned by Roa driver.

All those subject to this notice are referred to as “users” in this notice.

Our data practices are subject to applicable laws in the places in which we operate. This means that we engage in the practices described in this notice in a particular country or region only if permitted under the laws of those places. Please contact us here with any questions regarding our practices in a particular country or region.

III. Data collections and uses

A. The data we collect

Roa driver collects:

• Data provided by driver users to Roa driver, such as during account creation.

The following data is collected by or on behalf of Roa driver:

1. Data provided by driver users. This includes:

• User profile: We collect data when users create or update their Roa driver accounts. This may include their name, email, phone number, address, profile picture, payment or banking information (including related payment verification information), government identification documents, including driver’s license numbers and images, birthdate, signature, and photo. This also includes vehicle or insurance information of drivers and delivery partners, and user settings. We may use the photos submitted by drivers and/or delivery partners to verify their identities, such as through facial recognition technologies.

• Background check and identity verification: We collect background check and identity verification information for drivers and delivery partners. This may include information such as driver history or criminal record (where permitted by law), and right to work. This information may be collected by an authorized vendor on Roa driver’s behalf.

• Demographic data: We may collect demographic data about users, including through user surveys.

• User content: We collect the information users submit when they contact Roa driver customer support, provide ratings or compliments for other users or restaurant partners, or otherwise contact Roa driver. This may include feedback, photographs or other recordings collected by users.

B. How we use personal data

Roa driver collects and uses data to enable reliable and convenient transportation, delivery, and other products and services. We also use the data we collect:

• To enhance the safety and security of our users and services

• For customer support

• For research and development

• To enable communications between users

• To send marketing and non-marketing communications to users

• In connection with legal proceedings

Roa driver does not sell or share user personal data with third parties for their direct marketing, except with users’ consent.

Roa driver uses the data it collects for purposes including:

1. Providing services and features. Roa driver uses the data we collect to provide, personalize, maintain, and improve our products and services.

This includes using the data to:

• Create and update driver users’ accounts.

• Verify drivers’ and delivery partners’ identity, background history, and eligibility to work.

• Enable transportation, deliveries, and other services.

• Offer, process, or facilitate payments for our services.

• Offer, obtain, provide, or facilitate insurance, vehicle, invoicing, or financing solutions in connection with our services.

• Enable Accessibility features that make it easier for users with disabilities to use our services, such as those that enable deaf or hard-of-hearing drivers to alert their riders of their disabilities, allow only text messages from riders, and enable receipt of flashing trip request notifications instead of sound notifications on their mobile device.

• Perform internal operations necessary to provide our services, including to troubleshoot software bugs and operational problems; to conduct data analysis, testing, and research; and to monitor and analyze usage and activity trends.

2. Safety and security. We use personal data to help maintain the safety, security, and integrity of our services and users. This includes:

• Screening riders, drivers, and delivery partners before enabling their use of our services and at subsequent intervals, including through reviews of background checks, where permitted by law, to help prevent use of our services by unsafe drivers and/or riders.

• In certain regions, using information derived from driver’s license photos, and other photos submitted to Roa driver, for safety and security purposes.

• Using user ratings and feedback to encourage compliance with our Community Guidelines and as grounds for deactivating drivers and delivery partners with low ratings or who otherwise violated such guidelines in certain countries.

3. Customer support. Roa driver uses the information we collect (including recordings of customer support calls with notice to and the consent of the user) to provide customer support, including to:

• Direct questions to the appropriate customer support person

• Investigate and address user concerns

• Monitor and improve our customer support responses and processes

4. Research and development. We may use the data we collect for testing, research, analysis, product development, and machine learning to improve the user experience. This helps us to improve and enhance the safety and security of our services, improve our ability to prevent the use of our services for illegal or improper purposes, develop new features and products, and facilitate insurance and finance solutions in connection with our services.

5. Enabling communications between users. For example, a driver may message or call a rider to confirm a pickup location, a rider may contact a driver to retrieve a lost item, or a restaurant or delivery partner may call a delivery recipient with information about their order.

6. Marketing. Roa driver may use the data we collect to market our services to our users. This includes sending users communications about Roa driver services, features, promotions, sweepstakes, studies, surveys, news, updates, and events.

7. Non-marketing communications. Roa driver may use the data we collect to generate and provide users with receipts; inform them of changes to our terms, services, or policies; or send other communications that aren’t for the purpose of marketing the services or products of Roa driver or its partners.

8. Legal proceedings and requirements. We may use the personal data we collect to investigate or address claims or disputes relating to use of Roa driver’s services, or as otherwise allowed by applicable law, or as requested by regulators, government entities, and official inquiries.

D. Data sharing and disclosure

Some of Roa driver’s products, services, and features require that we share data with other users or at a user’s request. We may also share data with our affiliates, subsidiaries, and partners, for legal reasons or in connection with claims or disputes.

Roa driver may share the data we collect:

1. With other users

This includes sharing:

• Delivery recipients’ first name, delivery address, and order information with their delivery partner and restaurant. We may also share ratings and feedback, or other information to the extent required by law, with the restaurant partner and delivery partner.

• For drivers and delivery partners, we may share data with the rider(s), delivery recipient(s), and restaurant partner(s), including name and photo; vehicle make, model, color, license plate, and vehicle photo; location (before and during trip); average rating provided by users; total number of trips; length of use of the Roa driver app; contact information (depending upon applicable laws); and driver or delivery partner profile, including compliments and other feedback submitted by past users. We also provide riders and delivery recipients with receipts containing information such as a breakdown of amounts charged, driver or delivery partner first name, photo, route map, and such other information required on invoices in the country or region where the driver or delivery partner operates.

2. With the general public

Questions or comments from users submitted through public forums such as Roa driver social media pages may be viewable by the public, including any personal data included in the questions or comments submitted by a user.

3. For legal reasons or in the event of a dispute

Roa driver may share users’ personal data if we believe it’s required by applicable law, regulation, operating license or agreement, legal process or governmental request, or where the disclosure is otherwise appropriate due to safety or similar concerns. This includes sharing personal data with law enforcement officials, public health officials, other government authorities, airports (if required by the airport authorities as a condition of operating on airport property), or other third parties as necessary to enforce our Terms of Service, user agreements, or other policies; to protect Roa driver’s rights or property or the rights, safety, or property of others; or in the event of a claim or dispute relating to the use of our services. If you use another person’s credit card, we may be required by law to share your personal data, including trip or order information, with the owner of that credit card.

4. With consent

Roa driver may share a user’s personal data other than as described in this notice if we notify the user and they consent to the sharing.

E. Data retention and deletion

Roa driver retains user profile, transaction, and other personal data for as long as a user maintains their Roa driver account.

Roa driver may retain certain user data after receiving an account deletion request if necessary, such as to comply with legal requirements.

For drivers and delivery partners, Roa driver also retains vehicle and background check information (to the extent permitted by law) for as long as they maintain their Roa driver account.

IV. Updates to this notice

We may occasionally update this notice. Use of our services after an update constitutes consent to the updated notice to the extent permitted by law.

We may occasionally update this notice. If we make significant changes, we will notify users in advance of the changes through the Roa driver app or through other means, such as email. We encourage users to periodically review this notice for the latest information on our privacy practices.