Privacy Policy
This privacy notice lets you know how we promise to look
after your personal data. This notice tells you things like what information we
use to provide you with our bundle of transportation services, how we use your
information to keep you safe, and the choices and controls available to you.
This notice also tells you about your privacy rights and how data protection
rules work to protect everyone.
Pool Technology is the Controller of your personal data
unless otherwise stated below.
Our office address is :
Kirkos Subcity Ho. No 228/f-3 Addis Ababa, Ethiopia
We have nominated a Data Protection Officer, and you can
contact him at technology@pool.et or drop your message at our office address.
Please mark the envelope ‘Data Protection Officer’.
The term “us” or “we” refers to Pool Technology a private
limited company incorporated and registered under the laws of Republic of
Ethiopia.
The term “you” or “your” refers to the passenger or rider
who requests, hires and/or receives a transportation service through their Pool
app account.
1. Personal data we
process
We only process information that we need, so we can provide
you with the best service on our transportation marketplace.
• Contact
details: things like name, phone number and e-mail address. For some of our services
we might require a little more, like your home address.
• Profile
information: things like your profile picture, saved addresses, language and
communication preferences. For some of our services we might require a little
more, like your driver license details.
• Geolocation: we collect background location for driver app users to enable connect them with nearby riders who request trips. We collect location data of rider app to enable activities such as where you need a ride from, or the location of nearby vehicles to you,
the time, the journey progression and the final destination of your trip.
• Payment
information like the amount charged and the payment method used.
• Communication
and correspondence records such as when you engage with our in-app chat, or
speak with our customer service agents.
• Limited
identification data of the device, like the IP address, on which the Pool app
has been installed
• Data about
the usage of the transportation services: things like data about journey
status, times and data about your conduct as assessed by drivers.
• Data
related to communication through instant messages directly in the Pool app
("Chat with Driver" option): date and time of the communication and
its content.
• Other
user-generated content such as photos of parked vehicles.
2. Communications Data(Emergency Contact List).
We may upload your contacts list when you add emergency
contacts to the app. The emergency contacts help in communication when a user
is at risk or needs urgent help. Alerts are send to your contact persons incase
you face any danger during the trip. Pool can also use communication data for
wellbeing and security purposes, to enhance our services, and for
investigation.
3. Purpose of the
processing
We process your personal data so we can provide you with one
or more of our transportation services:
• We connect
you with a driver, help find you a scooter or hire a vehicle: We collect and
process personal data for the purpose of connecting passengers with drivers so
you can be picked up and dropped off; or to show you where our nearest
available hire-vehicles are located, such as our cars or scooters. Instant
messages directly in the Pool app are processed in order to provide service and
customer support (including resolving disputes between driver and rider), for
security purposes as well as to improve our products and services, and for
analysis.
• We get you
to where you want to go: We display geolocation data and the phone number of
passengers to drivers when ride-hailing to enable efficient pick-up and
drop-off, and make the journey and route transparent. This data is collected
only when the Pool app is activated. The collection of geolocation data stops
after closing the Pool app.
• We make
sure your journey goes smoothly: We use geolocation data to make sure you get
to your destination and resolve quality issues related to our services. We also
need to know where you choose to drop off a hire-vehicle so we can bill
correctly, recharge batteries and maintain our fleet.
• We make
sure the app is optimal: We use contact details to notify passengers and riders
of updates to the Pool app so you can keep using our services. We also gather
limited data from the device that you use to connect you with our internet,
mobile and telephone services, and to help keep your account safe through
authentication and verification checks.
• We make
sure your ride is the quickest, cheapest and most convenient to you: We collect
data on the routes taken by our passengers and riders to analyze geographic
coverage. This lets us do things like improve recommendations to the drivers
about the most efficient routes, and helps us make sure that our hire-vehicles,
like our scooters, are in the most convenient locations for customers.
• We collect
your payment: We obtain payment details to process passenger payment on behalf
of drivers for ride-hailing. And we process payments for our own hire-vehicles,
such as for our cars and scooters, too.
• We
maintain and promote standards: We collect data about journey statuses, time
and passenger ratings from driver feedback to encourage user safety, promote compliance
with our terms and conditions, and make sure we’re providing a quality and
enjoyable service to everyone. Customer support data and correspondence is
collected for the purposes of feedback, and resolving disputes and service
quality issues.
• We keep
you informed: Your name, phone number and email address will be used to
communicate with you for things like letting you know that your journey has
been completed, sending you trip confirmation slips and receipts, and letting
you know about important service updates such as when bad weather suspends the
hiring of ours scooters.
4. Legal Basis
We are allowed to use personal information in the ways
described above if we have a proper reason to do so. We always make sure we
have a good reason for doing anything with your data.
• Personal
data is generally processed in order to provide the services contracted through
the Pool app with you. This means that to give you the service we promised you,
and to meet our terms and conditions, we’ll process your personal data to meet
those obligations.
• We
generally in other circumstances process your personal data relying on
legitimate interest grounds. Legitimate interests include our commercial
interests in providing an innovative, personalised, safe and profitable service
to our passengers and partners, unless those interests are overridden by other
interests. Our legitimate interests also include things like investigating and
detecting fraudulent payments and other malicious activities, maintaining the
security of our network and systems, and responding to suspected or actual
criminal acts.
We may from time to time rely on alternative legal bases
when:
• it is
necessary to comply with a legal obligation such as for processing data when
the law requires it, including, for example, if there is a valid legal request
to disclose personal information to a third party such as a Court or regulatory
authority;
• to protect
your vital interests, or those of others, for example in the event of an
emergency or an imminent threat to life; or
• you have
given us clear consent to do so for another specific purpose in which you have
been fully informed.
If you choose not to give us personal information it may
prevent us from fulfilling the contract with you, or stop us doing something
expected of us in law. It may also mean that we cannot operate your account.
For example, we collect and process the personal data submitted by you in the
course of installing and using the Pool app; refusing to share geolocation data
via the App means we cannot direct a driver to your location for pick-up, nor
can we show you one of our own vehicles close to you for hire. We will not be
able to fulfil our obligations to you in other circumstances, for example,
should you refuse to undertake an identity verification check to ensure the
integrity of your account, then the account may be suspended or blocked to
prevent fraud.
5. Recipients
We only work with trusted partners and authorities. We only
share when there is a proper reason to do so. We limit sharing to only that
which is required. We do not sell your personal information.
• The
personal data of the passenger is only disclosed to the ride-hailing drivers
when they engage with a ride on in the Pool app; in such a case, the driver
will see the name, phone number and geolocation data of the passenger.
• After
providing the transportation service, the name and the telephone number of the
ride-hailing passenger will remain visible to the driver for 24-48 hours. This
is necessary for drivers to resolve any issues with the passenger like getting
something special back to you which might have been left in the car. Oops!
• Feedback
given by passengers regarding the quality of the ride-hailing service is
anonymous. Your rating is private between you and Pool.
• Depending
on the location of the passenger, the personal data may be disclosed to the
Pool group companies and partners (local subsidiaries, representatives,
affiliates, agents etc). Processing of personal data by Pool group companies
and partners will occur under the same strict conditions as established in this
privacy notice.
• In some
circumstances we are legally obliged to share information with external
recipients. For example, under a Court Order or where we cooperate with a data
protection supervisory authority in handling complaints or investigations. We
can also respond to requests, such as those from law enforcement agencies, when
we have a good-faith belief that the response is required by law in that
jurisdiction or furthers a public interest task, affects users in that
jurisdiction, and is consistent with internationally recognized standards. In
any scenario, we’ll always satisfy ourselves that we have a lawful basis on
which to share the information, and we’ll make sure that we document our
decision.
6. Security and
access
• Any
personal data collected in the course of providing our services is transferred
to and stored in the data centres of GCP. and/or Amazon Web Services, Inc.,
which are located in the territories of Member States of the European Union.
Only authorised employees of Pool group companies and partners have access to the
personal data and they may access the data only for the purpose of resolving
issues associated with the use of the services (including disputes regarding
transportation services).
• Pool group
companies and partners can access personal data to the extent necessary to
provide customer support in the respective country.
• For our
research and scientific purposes, all data, like bulk geolocation data, is
anonymised so you can never be identified from it.
6. Your rights and controls
We want you to stay in control of your personal data. Pool
provides you with controls through the app where you can view your personal
information including your profile data and trip history. We also offer in-app
settings like marketing opt-ins, and transparent cookie consent controls on our
website.
Your right of access
• You can
access your personal data via the Pool app. You have the right to ask us for
copies of your personal information. There are some exemptions, such as when we
have to balance the rights of others, which means you may not always receive
all the information we process.
Your right to rectification
• You can
access and update your personal data via the Pool app. You have the right to
ask us to rectify information you think is otherwise inaccurate. You also have
the right to ask us to complete information you think is incomplete.
Your right to erasure
• You have
the right to ask us to erase your personal information in certain
circumstances.
Your right to restriction of processing
• You have
the right to ask us to restrict the processing of your information in certain
circumstances. This means that your data can only be used for certain things,
such as legal claims or to exercise legal rights.
Your right to object to processing
• You may
have the right to object to processing if we are processing your information on
the basis of legitimate interests. You may submit an objection to any automated
decision we have made, and ask that a person reviews it.
Your right to data portability
• You have
the right to ask that we transfer the information you gave us from one
organisation to another, or give it to you, in certain circumstances. This only
applies to information you have given us.
7. Retention
Pool retains user data for only as long as necessary for the
purposes described above. This means that we retain different categories of
data for different periods of time depending on the type of data, the
transportation service it relates to, and the purposes for which we collected
the data.
• Your
personal data will be stored as long as you have an active passenger account.
If your account is closed, personal data will be deleted (according to our
retention schedule and rules), unless such data is still required to meet any
legal obligation, or for accounting, dispute resolution or fraud prevention
purposes.
• Financial
data regarding transportation services provided to passengers will be stored
for six months after the last journey. Data required for other accounting
purposes will be stored for seven years after the last journey.
• In the
event that there are suspicions of a criminal offence, fraud or false
information having been provided, the data will be stored as long as necessary
according to the internal, legal, and regulatory requirements.
• In case of
payment disputes, data will be retained until the claim is satisfied or the
expiry date of such claims.
• Journey
history data and the data about usage of transportation services will be stored
for three years, after which the data will be anonymized.
Please note that the deinstallation of Pool app in your
device does not cause the deletion of your personal data. If the Pool app has
not been used for three years, we’ll get in touch and ask you to confirm
whether you wish to keep your account active for future use. If no reply is
received in a reasonable time, the account will be closed and personal data
will be deleted unless such data is required for any purpose mentioned earlier
in this privacy notice.
8. Direct marketing
• We may
send direct marketing messages to your e-mail address and/or phone number when
you have given us permission to do so, or under a soft opt-in basis. We may
personalise direct marketing messages using information on how you use Pool’s
services, such as how frequently you use the Pool app, and your transportation
preferences.
• If you no
longer wish to receive direct marketing messages, please click the
"Unsubscribe" link in the footer of one of our emails, or opt-out in
the profile section of the Pool app. Easy.
9. Automated decision
making
We use help of automated decision-making in case of issuing
warnings and implementing ride hailing service suspension. Using automated
decision-making is less error-prone, more efficient and safer than using our
employees. Data about your usage of the transportation services (data about
journey status incl. cancellations and no-shows and data about your conduct as
assessed by drivers) is considered when assessing the need for a warning or
suspension. Ride hailing suspension will stay in force for 6 months, after
which access to ride hailing service will be restored.
You will always have the right for human review of the
decision and to contest the decision, express your point of view and obtain an
explanation by contacting our customer support in our app.
10. Dispute resolution
• Disputes
relating to the processing of personal data are resolved through customer
support technology@pool.et, in the first instance. You have the right to
contact Pool's Data Protection Officer admin@pool.et.
11. Making this
notice great
We hope you have found this privacy notice easy to
understand.
Data protection laws are important. They strengthen rules
and enhance your information rights. Many of these rules may appear
complicated, but most are grounded in common sense. We take our
responsibilities with your data seriously. Pool will continue to make changes
to this privacy notice as part of our commitment to protecting your privacy and
affording you even more transparency.
Further information is available in the local Terms and
Conditions for Passengers which can be located .