GreenRoute Privacy Notice 

I. Introduction. When you use GreenRoute, 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 policy which highlights key points about our privacy practices.

II. Overview.

Scope. This notice applies to users of GreenRoute’s services anywhere in the world, including users of GreenRoute’s apps, websites, features, or other services. This notice describes how GreenRoute 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 also governs GreenRoute’s other collections of personal data in connection with GreenRoute’s services. All those subject to this notice are referred to as “users” in this notice.

In addition, please note the following:

• For riders without a GreenRoute account: The personal data of drivers who utilize a users GreenRoute account. Personal data is processed in accordance with our contract with the owner of that account, and not as otherwise described in this notice. Such processing may include sharing of rider location data with the owner of that account. Please contact the owner of such account for more information.

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.

 

B. Data controller and transfer. GreenRoute is the data controller for the personal data collected in connection with use of GreenRoute’s services. We process personal data inside and outside of the United States. The personal data of users outside the United States is transferred on the basis of mechanisms approved under applicable laws.

 

III. Data collections and uses

A. The data we collect. GreenRoute collects:

• Data provided by users to GreenRoute, such as during account creation
• Data created during use of our services, such as location, app usage, and device data
• Data from other sources, such as GreenRoute partners and third parties that may use GreenRoute APIs

The following data is collected by or on behalf of GreenRoute:

1. Data provided by users. This includes:

• User profile: We collect data when users create or update their GreenRoute accounts. This may include their name, email, phone number, login name and password, address, profile picture, car make, car trim, car model, payment or banking information (including related payment verification information). For more information, please see the section below titled “How we use personal data.”
• Demographic data: We may collect demographic data about users, including through user surveys. In some countries, we may also receive demographic data about users from third parties.
• User content: We collect the information users submit when they contact GreenRoute customer support, provide ratings or compliments for other users or restaurant partners, or otherwise contact GreenRoute. This may include feedback, photographs or other recordings collected by users.

2. Data created during use of our services. This includes:

• Location data: We collect precise or approximate location data from a user’s mobile device if enabled by the user to do so. GreenRoute collects this data when the GreenRoute app is running in the foreground. In certain regions (which do not include the European Union), GreenRoute may also collect this data when the GreenRoute app is running in the background of the user’s mobile device. In addition, the location data collected from a User during a trip will be linked to the Users account, even if they have not enabled location data to be collected from their device, including for purposes of customer support, fraud detection, insurance, and litigation.
• Transaction information: We collect transaction information related to the use of our services, including date and time the service was provided, distance traveled, and payment method, if any. Additionally, if someone uses your promotion code, we may associate your name with that person.
• Usage data: We collect data about how users interact with our services. This includes data such as access dates and times, app features or pages viewed, app crashes and other system activity, type of browser, and third-party sites or services used before interacting with our services. In some cases, we collect this data through cookies, pixels, tags, and similar tracking technologies that create and maintain unique identifiers.
• Device data: We may collect data about the devices used to access our services, including the hardware models, device IP address, operating systems and versions, software, preferred languages, unique device identifiers, advertising identifiers, serial numbers, device motion data, and mobile network data.

3. Data from other sources. This includes:

• User feedback, such as ratings, feedback, or compliments.
• Users participating in our referral programs. For example, when a user refers another person, we receive the referred person’s personal data from that user.
• Users or others providing information in connection with claims or disputes.
• GreenRoute business partners through which users create or access their GreenRoute account, such as payment providers, social media services, or apps or websites that use GreenRoute’s APIs or whose APIs GreenRoute uses.
• Publicly available sources.
• Marketing service providers.

GreenRoute may combine the data collected from these sources with other data in its possession.

B. How we use personal data. GreenRoute collects and uses data to enable reliable and convenient transportation 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 send marketing and non-marketing communications to users
• In connection with legal proceedings

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

GreenRoute uses the data it collects for purposes including:

1. Providing services and features. GreenRoute uses the data we collect to provide, personalize, maintain, and improve our products and services. This includes using the data to:
   Create and update users’ accounts.
   Offer, process, or facilitate payments for our services.
   Enable features to personalize users’ GreenRoute accounts, such as creating bookmarks for favorite places, and to enable quick access to previous destinations.

1. 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:
   • Using device, location, profile, usage, and other data to prevent, detect, and combat fraud or unsafe activities.
   • Using user ratings and feedback to encourage compliance with our community guidelines.

3. Customer support. GreenRoute 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. Marketing. GreenRoute may use the data we collect to market our services to our users. This includes sending users communications about GreenRoute services, features, promotions, sweepstakes, studies, surveys, news, updates, and events.We may also send communications to our users about products and services offered by GreenRoute partners. Although we may send users communications about GreenRoute partners’ products and services, we do not sell users’ personal data to, or share it with, such partners or others for purposes of their own direct marketing or advertising, except with users’ consent.We may use the data we collect to personalize the marketing communications (including advertisements) that we send, including based on user location, past use of GreenRoute’s services, and user preferences and settings.

6. Non-marketing communications. GreenRoute 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 GreenRoute or its partners.
7. Legal proceedings and requirements. We may use the personal data we collect to investigate or address claims or disputes relating to use of GreenRoute’s services, or as otherwise allowed by applicable law, or as requested by regulators, government entities, and official inquiries.
8. Automated decision-making. We use personal data to make automated decisions relating to use of our services. This includes: Deactivating users who are identified as having engaged in fraud or activities that may otherwise harm GreenRoute, its users, and others.

 

C. Cookies and third-party technologies. GreenRoute and its partners may use cookies and other identification technologies on our apps, websites, emails, and online ads for purposes described in this notice. Cookies are small text files that are stored on browsers or devices by websites, apps, online media, and advertisements. GreenRoute uses cookies and similar technologies for purposes such as:

• Authenticating users
• Remembering user preferences and settings
• Determining the popularity of content
• Delivering and measuring the effectiveness of advertising campaigns
• Analyzing site traffic and trends, and generally understanding the online behaviors and interests of people who interact with our services

We may also allow others to provide audience measurement and analytics services for us, to serve advertisements on our behalf across the Internet, and to track and report on the performance of those advertisements. These entities may use cookies, web 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.

D. Data sharing and disclosure. Some of GreenRoute’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. GreenRoute may share the data we collect:

1. With other users – This includes sharing users daily and cumulative fuel/carbon savings.
2. At the user’s request – This includes sharing data with GreenRoute business partners. For example, if a user requests a service through a partnership or promotional offering made by a third party, GreenRoute may share certain data with those third parties. This may include, for example, other services, platforms, apps or websites that integrate with our APIs; those with an API or service with which we integrate; or other GreenRoute business partners and their users in connection with promotions, contests, or specialized services.
3. With the general public- Questions or comments from users submitted through public forums such as GreenRoute blogs and GreenRoute social media pages may be viewable by the public, including any personal data included in the questions or comments submitted by a user.
4. With the GreenRoute account owner – If a user requests transportation or places an order using an account owned by another party, we may share their trip information.
5. With GreenRoute subsidiaries and affiliates – We may share data with our subsidiaries and affiliates to help us provide our services or conduct data processing on our behalf.
6. With GreenRoute service providers and business partners – GreenRoute provides data to vendors, consultants, marketing partners, research firms, and other service providers or business partners. These include:

• Payment processors and facilitators
• Cloud storage providers
• Marketing partners and marketing platform providers, including social media advertising services
• Data analytics providers
• Research partners, including those performing surveys or research projects in partnership with GreenRoute or on GreenRoute’s behalf
• Vendors that assist GreenRoute to enhance the safety and security of its apps
• Consultants, lawyers, accountants, and other professional service providers
• Fleet partners
• Insurance and financing partners

7. For legal reasons or in the event of a dispute – GreenRoute 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, or other third parties as necessary to enforce our Terms of Service, user agreements, or other policies; to protect GreenRoute’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.This also includes sharing personal data with others 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.

8. With consent – GreenRoute 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. GreenRoute retains user profile, transaction, and other personal data for as long as a user maintains their GreenRoute account. GreenRoute may retain certain user data after receiving an account deletion request if necessary, such as to comply with legal requirements.

GreenRoute retains user profile, transaction, and other information for as long as a user maintains their GreenRoute account.

Users may request deletion of their account at any time by emailing us at accounts@greenrouteapp.com. Following such requests, GreenRoute deletes the data that it is not required to retain for purposes of regulatory, tax, insurance, litigation, or other legal requirements. For example, GreenRoute retains location, device, and usage data for these purposes for a minimum of 7 years; while it retains such data, it may also use it for purposes of safety, security, fraud prevention and detection, and research and development. In certain circumstances, GreenRoute may be unable to delete a user’s account, such as if there’s an outstanding credit on the account or an unresolved claim or dispute. Upon resolution of the issue preventing deletion, GreenRoute will delete the account as described above.

GreenRoute may also retain certain information if necessary, for purposes of safety, security, and fraud prevention. For example, if GreenRoute deactivates a user’s account because of unsafe behavior or security incidents, GreenRoute may retain certain information about that account to prevent that user from opening a new GreenRoute account in the future.

F. Grounds for processing. We only collect and use personal data where we have lawful grounds to do so. These include processing user personal data to provide requested services and features, for purposes of GreenRoute’s legitimate interests or those of other parties, to fulfill our legal obligations, or based on consent. We collect and use personal data only where we have one or more lawful grounds for doing so. Such grounds may vary depending on where our users are located, but generally include processing personal data:

1. To provide requested services and features. In order to provide our services, we must collect and use certain personal data. This includes:

• User profile data, which we use to establish and maintain user accounts; verify user identity; communicate with users about their trips, orders, and accounts; and enable users to make payments or receive earnings
• Background trip information, which is used to verify an applicant’s eligibility to be a driver or delivery partner
• Driver and delivery partner location data, which we use to track trips and assist with navigation
• Usage data, which is necessary to maintain, optimize, and enhance GreenRoute’s services, including to determine incentives, connect riders and drivers, and calculate costs of trips and driver earnings
• Transaction information
• Information relating to customer support

2. For purposes of the legitimate interests of GreenRoute or other parties. This includes using personal data to maintain and enhance our users’ safety and security. For example, this includes purposes such as combating fraud; improving our services, direct marketing, research, and development; and enforcing GreenRoute’s Terms of Service.

In addition, it includes using personal data to the extent necessary for the interests of other people or the general public, such as in connection with legal or insurance claims, and to protect the rights and safety of others.

3. To fulfill GreenRoute’s legal obligations. For example, GreenRoute is subject to laws and regulations in many cities and countries that require it to collect and retain data about our users’ trips, and to provide copies of such data to the government or other authorities. We collect and use personal data to comply with such laws. GreenRoute may also share data with law enforcement regarding criminal acts or threats to public safety, or requests by third parties pursuant to legal processes.
4. With consent. GreenRoute may collect and use personal data based on the user’s consent. For example, we may collect personal data through voluntary surveys. Responses to such surveys are collected on the basis of consent and will be deleted once no longer necessary for the purposes collected. A user who has provided consent to a collection or use of their personal data can revoke it at any time. However, the user will not be able to use any service or feature that requires collection or use of that personal data.

 

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 GreenRoute apps or through other means, such as email. We encourage users to periodically review this notice for the latest information on our privacy practices. After such notice, use of our services by users in countries outside the European Union will be understood as consent to the updates to the extent permitted by law.

 

Last modified: January 20, 2020

Effective date: January 20, 2020