PRIVACY NOTICE

This privacy notice explains how Forus Taxi OÜ (registration code 12600455, address Rotermanni tn 8, Tallinn 10111, Estonia) (hereinafter “Forus Taxi” or “us”) collects and processes your personal data if you have joined the US Tokens Programme (hereinafter “Programme”) on the mobile app “Forus Taxi” (hereinafter “Platform”).

Forus Taxi is the controller of personal data processed on the Platform in connection with the Programme. Forus Taxi is the controller of personal data within the Programme only to the extent that it is related to the reservation of tokens on or through the Platform within the Programme. Forus Taxi’s general privacy policy (https://forus.eu/en/et/terms-and-privacy) applies in other respects than the processing of personal data within the Programme. Personal data is any data about an identified or identifiable natural person. The privacy notice has been drawn up and personal data is processed in accordance with the General Regulation (EU) 2016/679 on the protection of personal data (hereinafter referred to as “GDPR”) and the legislation of the Republic of Estonia regulating the protection of personal data. Forus Taxi makes every effort to ensure a high level of personal data protection. We ask you to read the privacy notice carefully, as it contains, among other things, important information about your rights as a data subject.

• PROCESSING OF PERSONAL DATA ON THE FORUS TAXI PLATFORM IN CONNECTION WITH THE PROGRAMME

1. What personal data do we process?

We receive personal data directly from you if you use the Platform as a natural person and join the Programme.

As a controller, we collect and process your following personal data:

• personal identity data (e.g. name); 
• user account data (e.g. driving history); 
• contact information (e.g. phone number and e-mail address); 
• details of transactions performed (e.g. cost of rides and method of payment); 
• analytical data about the use of the Platform and websites; 
• data on US tokens accumulated or reserved for you; 
• other data that you provide to us at your own request, including through the contact form.

 

1. Purposes and legal bases for the processing of personal data

Forus Taxi processes your personal data for the following purposes and legal bases:

• • to enable you the use of the Platform’s functions and features in connection with participation in the Programme. The legal basis for processing personal data for this purpose is the performance of a contract with you (GDPR art. 6 (1)(b));
  • To fulfill Forus Taxi’s legal obligations in connection with the Programme (GDPR art. 6 (1)(c)). Such obligations may be, for example, obligations arising from the Accounting Act; 
  • to respond to your inquiries and to communicate with you regarding your participation in the Programme. The legal basis for processing personal data for this purpose is our legitimate interest in responding to your inquiries (GDPR art. 6 (1)(f));
  • to inform you about information related to the Programme (including events related to the Programme) and additional opportunities. The legal basis for the processing of personal data for this purpose is our legitimate interest in providing you with the aforementioned information (GDPR art. 6 (1) (f)) or in the cases stipulated by legislation, your consent (GDPR art. 6 (1) (a));

• to improve the quality of our Platform in relation to the Programme and to perform analytics for this purpose. The legal basis for personal data processing for this purpose is our legitimate interest in improving and further developing our services (GDPR Article 6(1)(f)).

• TRANSFER AND DISCLOSURE OF PERSONAL DATA

We will do our utmost to keep your personal data secure and therefore require our employees and partners to maintain strict security and confidentiality. Access to your personal data is restricted to our employees and partners who need access to that information to perform their duties.

Forus Taxi may, for the purposes set out in this Privacy Notice, disclose your personal data (first and last name, e-mail address, date of birth, phone number, information on the tokens collected and country of origin) to the following third parties where this is necessary for the purposes set out in this Privacy Notice and permitted by applicable law:

 

• entities belonging to the same group as the controller (Forus International OÜ (registration code 16247286) group) to the extent that it is necessary for the implementation of the Programme;

• to Programmable Equity OÜ (registry code 16320994; hereinafter “KOOS Environment”), which provides an online software platform, which registers Programme’s participants, to the extent that it is necessary for the implementation of the Programme;

– to our cooperation partners, whom we use to better organize our activities (e.g. IT service providers). In such cases, we ensure that all persons to whom we transfer your personal data process personal data strictly in accordance with our instructions, to the extent limited by the legal basis of personal data processing, purposefully, to the minimum necessary extent and otherwise in accordance with the applicable data protection law; 

– to public institutions, if the transfer of personal data is necessary to fulfill their obligations arising from the law or to prevent or investigate possible crimes; and to other third parties if it is necessary to protect their property and rights or defend themselves against legal claims.

In general, we do not transfer your personal data outside the European Economic Area. When we do so, we will implement appropriate safeguards to ensure that such transmission is compliant with applicable law and secure. In connection with the transfer of personal data to countries that do not provide an adequate level of data protection, Forus Taxi uses appropriate protection measures when transferring personal data, for example using the European Commission’s standard data protection clauses in personal data transfer agreements. You can review the applicable safeguards by contacting us at [email protected]. 

3. RETENTION OF PERSONAL DATA

We retain your personal data only as long as necessary to achieve the purposes described in the privacy notice or in accordance with applicable law. If the storage of your personal data is no longer required by law or necessary to achieve the purpose of its storage, we will permanently delete or anonymize your personal data, unless you have given us instructions to the contrary and we have not entered into an agreement for longer-term data storage.

4. SECURITY

We use appropriate technical and organizational security measures (including physical, electronic and administrative) to protect your personal data against loss, destruction, misuse, unauthorized access or disclosure.

Please note that while we strive to take reasonable measures to protect the security of your personal information, no system can completely eliminate all potential security risks.

5. PUSH NOTIFICATIONS 

As part of the Programme, you can voluntarily agree to receive push notifications by pressing the “Allow” button. These notifications may appear on your mobile device as various messages, sounds, icons, banners and other notifications. The purpose of push notifications is to provide you with personalized offers and notifications according to your preferences and interests, which we have identified based on the Programme, based on our legitimate interest. For this purpose, we use your name, actions related to the use of the service, contact data, the ID of the mobile device used and other related data. You can turn off the subscription to push notifications at any time in the settings of your mobile device or in the application. You can also voluntarily subscribe to similar messages and notifications for the same purposes via web browsers and e-mails. You can turn off the subscription to push notifications at any time in the settings of your web browser. 

We may share the aforementioned data with our trusted partners who provide us with tools to perform analytics, and with companies belonging to the same group as us.

6. RIGHTS OF THE DATA SUBJECT

As a data subject, you have the following rights, in accordance with the applicable laws on the protection of personal data and subject to any limitations on the exercise of those rights under those laws: 

– The right to be informed of the personal data processed concerning you as a data subject; 

– The right to rectification of personal data in the event of inaccuracy of personal data; 

– The right to obtain the erasure of personal data, unless the controller can legitimately refuse (where we have a legal basis for continuing to store the data);

– The right to request restriction of processing; 

– The right to object to the processing of your personal data; 

– The right to the transfer of personal data; and 

– The right to withdraw consent to the processing of personal data at any time where the processing of personal data is based on consent. 

To exercise your rights, or if you have any questions, please contact us by email at [email protected]. We also ask you to contact us if you believe that we have processed your personal data in breach of applicable law. If you believe that we have processed your personal data unlawfully, you also have the right to take legal action or lodge a complaint with the Data Protection Inspectorate, whose contact details can be found at www.aki.ee.

7. AMENDMENTS TO THE PRIVACY NOTICE

This Privacy Notice may change from time to time. If we make any changes to the Privacy Notice, we will notify you on the Platform, where you can also find the latest version of the Privacy Notice. In the event of material changes, we will also notify you by email to the email address you have registered within the Platform or subsequently provided to us.