Carpooling Program Website and App Privacy Policy

Faxi Ltd., Unit 23 Canalot Studios, 222 Kensal Road, London, W10 5BN, United Kingdom (Controller for the Processing of your Personal Data pursuant to Article 4(7) of the General Data Protection Regulation (hereinafter referred to as the “GDPR”).

  1. Introduction

The purpose of this Privacy Policy is to inform you on the processing of your Personal Data when visiting our website, our mobile websites and applications (“App”) of Faxi Ltd. (hereinafter « Faxi », « we » or « us ») to form carpools. Personal Data means any information relating to you that identifies you, or through which you can be identified, such as a name, an identification number, location data, or an online identifier. This Privacy Policy explains how we collect, use and disclose your Personal Data when you use our website and/or App to participate in the carpooling services offered by us.

1.2.      Contact Information of Data Protection Officer of the Controller

Faxi Ltd.,
Data Protection Officer
Unit 23 Canalot Studios,
222 Kensal Road,
London W10 5BN
United Kingdom
E-mail: francois.planke@faxi.co.uk

  1. Description of Personal Data Collected, the Purposes and Legal Basis for processing your Personal Data

2.1       Provision of Carpooling Services

The carpooling services offered through Faxi allows anyone to register to carpool free of charge by registering as a user over the mobile App or on the website free of charge, provided that their carpool groups do not exceed 20 users per group. The software App offers you the opportunity to create your own closed (access is controlled by the Community administrator) carpooling community. Anyone can set up a community and invite their friends or colleagues to join for free. Any carpooling groups involving more than 20 users will only be offered free of charge through Faxi’s corporate carpooling programs offered to only employees of its business customers. If you register under the Corporate Carpooling Program through your employer, please see Section 2.6 Corporate Carpooling below for more information about the information we collect, the purpose of the processing and with whom we share it.

2.2       Your Registration and Participation in our Carpooling Services:

To use our services, you need to create an account on either our website or through our mobile App, you need to have agreed to our Terms and Conditions (T&Cs) and you need to be at least eighteen (18) years old. You will also need to provide us with your consent to track your location and activities since this is an integral part of the carpooling service (see Activity Data in Section 2.3 below). We collect Personal Data from you when you register to use the carpooling services and complete the user sign-up process, or to allow you to join or create closed-user-carpooling groups, send emails to us or request further information about anything on the website or the App.

The types of information that we collect and store are:

  • name,
  • address,
  • email address,
  • the date and time of the requested ride-sharing,
  • pick-up or drop-off destination points
  • information about who you are, such as specific workplace authentication,
  • information such as a pass number, or vehicle registration, the type of vehicle you drive, as well as other data that you submit in your profile, such as your photo or your “nickname”

The legal basis for processing the Personal Registration Data that you provide to use is based on fulfillment of our pre-contractual and contractual obligations to you in accordance with Article 6 (1)(b), your consent in accordance with Article 6 (1) (a) of the GDPR and in accordance with our T&Cs.

2.3       Your Activity Data

When you access and interact with our website or App, we need to track your activities to enable you to connect to our website and App. We use tracking cookies to identify you in performance of this service, information of which is provided in detail under the Cookies Section 2.10 and in the Cookie List in Section 9 below. Our servers also receive and record information about your computer, device and browser, including potentially your IP Address, browser type, and other software and hardware information. If you access our website and/or App from a mobile or other device, we may collect a unique device identifier assigned to that device, location data or other transactional information for that device. The recording of activity data is necessary for the provision of the Carpooling as described in our T&Cs, since without it we cannot identify your location to place you with registered users along your route, or provide you with incentives offered by your employer as part of the Corporate Carpooling Program. We use this information to verify which route you choose and the actual performance of a car pool. We also use this data to identify other users who wish to commute in the same direction to match the users and allow the building of carpools. We also use your location to provide you with important traffic updates and real-time transmissions about possible pick-ups within your area.

With your consent, we also collect information about your activities throughout your journey, such as your location and the time that you arrive, information about with whom you carpool, and the routes that you choose. The Personal Data that we collect about your activities are for example:

  • Specific geographic locations, such as through GPS, Bluetooth or WiFi signals for the provision of our proof of ride share service, to include geolocation accelerometer and compass information, which is combined with your unique user ID. This helps us connect you with users in your area.
  • Through your unique user ID, we allocate the time and date of your carpooling activities, and the number of passengers in a vehicle, and the location of your drop-off, pick up and stops along the way.

We only collect your location data and share it with others to the and based on your consent pursuant to Art. 6 (1) (a) GDPR. You may withdraw your consent at any time through your settings or in accordance with Section 6 below. Upon withdrawing consent, you will no longer be able to use the App. In this case, we will freeze your account and delete any Personal Data in accordance with Art. 6 GDPR.

2.4       Text Messaging and Email Correspondence

You may want to communicate with other users or with us through our messaging service available through our App and on the website. During your correspondence, you will provide us with Personal Data, which we will process to respond to you and provide the carpooling services. The information that you share with us or with other users will be stored in your account until you delete it.

2.5       Customer Surveys

To continuously improve our products and services and adapt them to your needs, we regularly invite our users to participate in customer surveys. In doing so, exercise our legitimate business interest under Article 6(1)(f) GDPR to use the information you provide during the carpooling registration process (Section 2.2 above) to contact you and ask you for your feedback on your experience.

2.6       Corporate Carpooling Program

Participation in the corporate carpooling program requires the user to register as an employee of a Faxi carpooling client via their company email address allows those employers to offer benefits to their employees who choose to use more environmentally-friendly modes of transportation, such as carpools, taking public transportation or riding a bicycle to and from work. Employee participation in the carpooling program is completely optional. If you sign up, your employer will provide you with certain benefits depending on whether and how often you participate in carpools and use our services to build carpools.

We only share your Personal Data that is necessary to run the Website and the App and for you to receive the incentive-benefits that may be offered by your employer, such as premium reserved parking, free coffees, lunch, etc. Your Employer receives aggregated data about carpooling activities. You will be allocated a unique User ID, and we will illustrate to your employer through our carpooling dashboard on our website your carpooling activities. Through your User ID, your employer identifies who the frequent carpoolers are, the length of their journey, etc. Your employer offers incentives for building and using carpools. Based on the information we provide to your employer, you may be entitled to receive certain benefits from them directly. Depending on what kind of benefits your employer is offering, it may be necessary for us to provide your employer with certain Personal Information to provide you the benefits, such as a prize or coupon. We will only do this with your consent.

2.6.1    Sharing the Information you provide us with Users in your Carpooling Group and your Employer

You provide us with information about yourself, where you want to go, with whom you want to commute, which routes you take, etc. and we share this with other users in your groups and with your employer for them to provide you with your incentive benefits directly. If you do not give us your consent or withdraw your consent to share your information, we will no longer be able to provide you with the services described in our T&Cs.

2.7       Safe Driving Scores

Only if you provide us with your consent, we will process your Personal Data to create a Safe Driver Score for you. Your Safe Driver Score can let you know how you are driving, give you indications on how to drive more safely, and may enable you to receive discounted insurance quotes from insurance providers, subject to your Personal Data being passed to such insurance providers by us. You may withdraw your consent for this any time by adjusting your settings located in your profile.

2.8       Marketing

2.9       Sensitive Information

We ask that you do not send us, and you do not disclose, any sensitive personal information (such as information related to racial or ethnic origin, political opinions, religion or other beliefs, health, criminal background or trade union membership) on or through this website, App or otherwise. However, if we do need to collect such information from you to fulfill our contractual requirements in providing the carpooling services, we would only process a special category of personal data with your prior explicit consent for a specific purpose stated in your consent.

2.10     Our Use of Cookies

2.10.1  Description of our Cookies

Our website and Apps use cookies to perform the carpooling services pursuant to your contract with us and pursuant to our contract with your employer. Other cookies are also used for the improvement of the website and App performance. Cookies are small text files that store information on the web browser in the memory of your device. Thus, we can obtain certain information. Cookies cannot run programs or transmit viruses to your computer. As is true of most websites and Apps, we gather certain information automatically and store it in log files. You can see the full list of the Cookies that we use for the website and for the App for what purpose these cookies are required in Section 9 below. In addition, the deactivation/deletion of cookies only affects the internet browser used for this purpose.

2.10.2  Types of Cookies

This website uses cookies, which are described below to provide the carpooling services in accordance with Article 6 (1) (a) GDPR and in accordance with Article 6.1(f) GDPR, our legitimate business interest in improving user experiences during the carpooling journey:

Functionality of the website: Cookies that are necessary for our website or App to function technically or that offer a service or option you have requested; e.g. a cookie that “remembers”   your personal settings, such as selected language or similar.

  • Performance Analysis of the Website: We are constantly striving to improve our website and App. For this purpose, we use cookies that provide us with overall statistics on the number of visitors, which areas of a page are viewed most, information on the city or location of the users and the length of their stay, etc.
  • Tracking Cookies: We use cookies to provide you with the best carpooling services and to record your journey to enable you to take advantage of the incentive programs offered by your employer.
  • Google Analytics: We use Google Analytics in conjunction with IP anonymization. The IP address within the European Economic Area (EEA) will be abbreviated before the transmission to the USA. The IP address transmitted by Google Analytics is not merged with other Google data. For such exceptional cases, in which personal data is transferred to the USA, google has submitted to the EU-US Privacy Shield, https://www.privacyshield.gov/EU-US-Framework.
  • Social Media Cookies: To share content from our website or App via social media channels such as Facebook or Twitter, a cookie must be installed on your device. Further information can be found in the guidelines of the respective company and in Section 10 below.

2.10.3  Deactivation/Deletion of Cookies

To prevent the use of cookies by your internet browser or on your mobile device, you can deactivate the use of cookies in your settings (see also https://support.apple.com for iOS devices, and https://support.google.com for Android devices). Furthermore, cookies that have already been set can be deleted at any time via an internet browser or other software programs in your App. You can use the help functions of your internet browser to learn how to deactivate and/or delete cookies. If you deactivate or delete the cookies, it will result in certain functions of our website or our App no longer functioning and you will no longer be able to use the service. For other internet browsers, the deactivation/deletion of cookies must be repeated accordingly. If you de-install the App, no more information will be collected.

2.10.4  Duration of the Cookies

We store and process the data until the end of the term of a respective cookie or until you delete the cookies or withdraw your consent.

  1. Recipients of your Personal Data

3.1       Service Providers

We engage third parties to perform certain services and tasks necessary for the provision of the platform for carpooling and the handling of issues that require special know-how and special IT-Infrastructure that cannot be taken over internally. The hosting of our website, processing of the processes concerning the formation and handling of carpooling activities and providing the software technology and updates to support the platform for the formation and performance of carpooling are outsourced. We will share your personal information with our technical service providers, who will process your information only as instructed by us and only in the ways that are described in this privacy policy and the T&Cs.

3.2       Other Carpooling Users in your Company

We share the Personal Data that you provide us through your use of the carpooling services with other employees in your company who have registered to use the carpooling services. The sharing of information is necessary for the performance of the services and the users only receive information you provide when you create or join a carpooling group. Keep in mind that if you share your Personal Data through Social Media Plug-Ins, by activating the share or like button, then your Personal Data will be displayed outside of your closed-user carpooling group.

3.3       Your Employer

As described in Section 2.6.1 above, we share information about your carpooling activities with your employer to perform the carpooling services and to provide you with incentives. For more information on how your employer uses the information we share with them, you will need to refer to your employment privacy policy.

3.4       Data Transfer due to a Legal Obligation

If we are obligated to transfer your data to a third party based on a legal obligation or in order to comply with applicable laws and governmental bodies, we will do so in accordance with Article 6 (1) (c) GDPR. This may include for example, defense or pursuit of our legal claims involving your use of the carpooling services, investigate fraud, cooperating with criminal investigations, such as compliance with a subpoena, or similar legal process, or to the data protection supervisory authority.

  1. Data Retention

We will retain your information for the period necessary to fulfill the purposes outlined in this Privacy Policy and as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. We delete your Personal Data that is no longer necessary, when you withdraw your consent or when you delete the App. If the data are not deleted because they are necessary for other and legally permissible purposes, their processing is restricted. This means that the data is blocked and not processed for other purposes.

Remember that after you cancel your account, copies of some information from your account may remain viewable in some circumstances where, for example, you have shared information with social media or other services. We will use our best endeavors to contact any third parties to request the deletion of your data, if you request this.

  1. What rights do you have regarding to the processing of your information?

In order to inform you of all possibilities within the scope of the collection and use of your information/personal data, we would like to draw your attention to the rights you are entitled to in this context.

5.1       Right of Access

You can request information on how, by whom, for what purposes and under what conditions your data is collected and used.

5.2       Right to Rectification

We do not want to transfer false or outdated information in the context of the use of your personal information, e.g. to prevent misunderstandings or possible damages. Therefore, you have the opportunity to update or correct the information we have collected about you at any time.

5.3       Right to restriction of processing

You can also ask us to use your data only to a limited extent. This means that your data may still be stored but may only be used for limited purposes (e.g. to assert legal claims).

5.4       Right to object

If we collect and use your information on the basis of legitimate interests, you have the right to object to the use of your information.

5.5       Right to lodge a complaint with a supervisory authority

It is important to us to comply with all laws and provisions regarding your data. However, if you believe that by using your data we are in breach of the General Data Protection Regulation, you have the right to lodge a complaint with a supervisory authority.

5.6       Right to erasure

We also delete your data insofar as they no longer required for the purposes stated herein and if we are not obliged to retain them (see also Section 4). However, if you believe that there is no legal reason for further storage, you can assert your right to erase the data.

5.7       Right to data portability

You also have the right to transfer any data you have provided to us. This means that we provide you with this data in a structured, common and machine-readable format.

  1. Consent and withdrawal of Consent

If you have given us your consent for the processing of your personal data, you can withdraw this at any time. Please note, the withdrawal has no effect on the legality of the data processing carried out in the past on the basis of your consent. To exercise your right to withdraw consent go to your profile and uncheck the consent box. Keep in mind, that we will be unable to provide you with carpooling services if you withdraw your consent for us to track your activities and such withdrawal will result in the termination of our T&Cs. Your User Account will be deactivated and your Personal Data will be deleted.

  1. Right to Lodge a Complaint with the Supervisory Authority

You can also contact us if you wish to complain about how we collect, store and use your personal data (see contact data of Data Protection Officer in Section 1.3 above). It is our goal to provide the best possible remedy with regard to your complaints. However, if you are not satisfied with our answer, you can also contact the competent supervisory authority.

  1. Changes to this Privacy Policy

We reserve the right to update this privacy policy from time to time. Updates to this privacy statement will be published on our website. Changes apply as soon as they are published on our website. We therefore recommend that you visit this page regularly to find out about any updates that may have been made.

  1. For further information on how we process personal information by means of cookies please refer to the following Cookie Table here:

Cookies used for the Website:

Nr. Cookie
Name
Personal Data Collected and Purpose for Collection Cookie Type Provider Cookie
Duration
Webseite
1.   alogin This cookie contains the email address of the currently logged in user.

It is used for maintaining the user’s session to keep them logged in. It is also remembers the user information for the next session.

Functional Faxi Persistent

 

https://faxi.co.uk/
2.   session This cookie contains the session ID of the currently logged in user.

It is used for maintaining the user’s session to keep them logged in. It is also remembers the user information for the next session.

Functional Faxi Persistent https://faxi.co.uk/
3.   oid This cookie contains the active organization ID of the currently logged in user.

It is used to enable the core carpooling functionality of the webpage, for example, it navigates you to the carpooling community you select.

Functional Faxi Persistent https://faxi.co.uk/
4.   _map_traffic_layer This cookie contains the information about the traffic congestion on the current map section.

It is used to enable the real-time traffic congestion display on the discovery map.

Functional Faxi 1 Week https://faxi.co.uk/
5.   _map_selected_route This cookie contains the information about the current user’s selected carpooling route.

It is used to enable the core functionality of the discovery map, such as selecting the best routes currently available and it remembers your preference the next time you log in.

Functional Faxi 1 Month https://faxi.co.uk/
6.   _map_users_on_route_json This cookie contains the information about the available users on current user’s selected carpooling route.

It is used to enable the core functionality of the discovery map, for example, it shows you the users available on your route.

Functional Faxi 1 Week from the date of your last log in https://faxi.co.uk/
7.   _ga Google Analytics Cookie

This cookie enables an analysis of user behavior when visiting the website. We use Google analytics in conjunction with IP anonymization.

Analytical Google 2 Years https://faxi.co.uk/
8.   _gid Google Analytics Cookie

This cookie enables an analysis of user behavior when visiting the website. We use Google analytics in conjunction with IP anonymization.

Analytical Google 2 Days https://faxi.co.uk/
9.   _gid_gtag Google Analytics Cookie

This cookie enables an analysis of user behavior when visiting the website. We use Google Analytics in conjunction with IP anonymization.

Analytical Google 1 Hour https://faxi.co.uk/
10. _gat Google Analytics Cookie

This cookie enables an analysis of user behavior when visiting the website. We use Google Analytics in conjunction with IP anonymization.

Analytical Google 1 Hour https://faxi.co.uk/

Cookies used for the App:

Nr. Cookie Name Personal Data Collected and Purpose for Collection Cookie Type Provider Cookie Duration Apps
1.   alogin This cookie contains the email address of the currently logged in user.

It is used for maintaining the user’s session to keep them logged in. It is also remembers the user information for the next session.

Functional Faxi Persistent

 

iOS & Android
2.   session This cookie contains the session ID of the currently logged in user.

It is used for maintaining the user’s session to keep them logged in. It is also remembers the user information for the next session.

Functional Faxi Persistent iOS & Android
3.   oid This cookie contains the active organization ID of the currently logged in user.

It is used to enable the core carpooling functionality of the app, for example. It identifies which carpooling community you’re part of.

Functional Faxi Persistent (You can be part of more communities with the same alogin & session. So this changes according to the will of the user, but is destroyed on logout or session not being active anymore.) iOS & Android
  1. Social Media Plug-Ins

We have also implemented Facebook’s, Google+’s, YouTube, and LinkedIn social plug-ins on our website and App. You can recognize the provider of the plug-in by the marketing by his initial letter or the logo on the respective icon. We use the so-called “two-click solution”. As a result, no personal data is passed on to the providers of the plug-ins during a purely informational visit to our website or App. We offer you the possibility to communicate directly with the provider of the plug-in via the “share” or “like” button. Only if you click on the marked field and thereby activate it, the plug-in provider receives the information that you have accessed our website or App. The data is transferred regardless of whether you have an account with the plug-in provider and are logged in there. If you are logged in with the plug-in provider, your data collected with us will be directly assigned to your existing account with the plug-in provider. If you click the activate button and, for example share the page, the plug-in provider will also store this information in your user account and will share it publicly with your contacts.

Through the plug-ins we offer you the possibility to interact with your social networks and other users, so that we can improve our offer and make it more interesting for you as a user. The plug-in provider stores the data collected about you as user profiles and uses these for the purposes of advertising, market research and demand-oriented design of its website. Such an analysis takes placer (also for not logged in users) for displaying of demand driven advertisement and in order to inform other users of the social network about your activities on our website.

For more information on the purpose and scope of data collection and its processing by the plug-in provider, please refer to the privacy policies of the respective providers as notified below. There you will also receive further information on your rights in this regard and setting options for the protection of your privacy. Below we have listed the addresses of the respective plug-in providers and URL with their data protection information:

Facebook

Plugins of the social network Facebook that involve the processing of information within the European Union is operated by Facebook Ireland Limited, Hanover Reach, 5-7 Hanover Quay, Dublin 2, Ireland (« Facebook »). Information on Facebook’s data protection: http://www.facebook.com/policy.php. Facebook has also submitted to the EU-US Privacy Shield, https://www.privacyshield.gov/EU-US-Framework.

Google + and YouTube

Plugins of the social network Google; is operated by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (« Google »). An overview of the Google+ plugins and their appearance can be found here: https://developers.google.com/+/plugins; information on data protection at Google+ can be found here: http://www.google.de/intl/de/policies/privacy/. Google has also submitted to the EU-US Privacy Shield, https://www.privacyshield.gov/EU-US-Framework.

LinkedIn

Plugins of the social network LinkedIn is operated by LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2,Ireland; https://www.linkedin.com/legal/privacy-policy.

LinkedIn has submitted to the EU-US-Privacy-Shield, https://www.privacyshield.gov/EU-US-Framework.

  1. Links to Social Media Websites

You will also find links to social media networks such as Facebook, Twitter, Google+, YouTube, LinkedIn and Xing on our website. These are not social plug-ins provided by the social media provider, which already transmit data to the provider when the page is loaded without the users having any influence. Behind the buttons to the social media networks there is only a link to the social media network including the transfer of the website to be shared. No user data is transmitted from the website to the social media network. If you are already logged in to the respective social media service at the time you click the button, the sharing dialog will recognize this so that you can share the content directly. If this is not the case, you will be asked to log into the social media network. From this point on you will be on the website of the respective social media network. Please find the information on data processing of the respective providers below.

Facebook

Facebook Ireland Limited, Hanover Reach, 5-7 Hanover Quay, Dublin 2, Ireland (« Face-book »). Information on Facebook’s data protection : http://www.facebook.com/policy.php. Facebook has also submitted to the EU-US Privacy Shield, https://www.privacyshield.gov/EU-US-Framework.

Twitter

Twitter,Inc. 1355 MarketSt,Suite 900, San Francisco, California 94103, USA; https://twitter.com/privacy. For more information and customization options, see:

Twitter has submitted to the EU-US Privacy Shield, https://www.privacyshield.gov/EU-US-Framework.

Google + and YouTube

Google+ and YouTube are operated by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (« Google »). Information on data protection at Google+ can be found here: http://www.google.de/intl/de/policies/privacy/. Google has also submitted to the EU-US Privacy Shield, https://www.privacyshield.gov/EU-US-Framework.

LinkedIn

LinkedIn operates from Ireland with regard to its activities in in the European Union, under LinkedIn Unlimited Company, Wilton Place, Dublin 2,Ireland; https://www.linkedin.com/legal/privacy-policy.

LinkedIn has submitted to the EU-US-Privacy-Shield, https://www.privacyshield.gov/EU-US-Framework.