PRIVACY POLICY

Last updated: July 20, 2023

Welcome to InDrive.Delivery. Ensuring your privacy is a key principle of our work. This policy describes how we process your personal data, what data we collect, for what purposes we use and transfer it, as well as outlining your rights and your choices regarding your data.

This policy applies wherever InDrive.Delivery is available, except for the countries where a jurisdiction-specific privacy policy is in place. We will comply with applicable local laws in relation to all practices described in this policy. If there is an inconsistency between this policy and the local law, we will comply with the local law to the extent of the inconsistency.

SUOL INNOVATIONS LTD is the entity that provides InDrive.Delivery and controls the processing of data ("we" or "us").

This policy applies to all users of the InDrive.Delivery mobile application ("App") and any services that we provide through the App ("Services"), as well as when contacting us by phone, email, correspondence, on social media, in person, or through other means of communication. This policy does not apply to the data processing of our employees, corporate partners, contractors, and subcontractors, but it does apply to the data processing of Couriers.

Users of the App are referred to as "Couriers".

What information we collect

We collect three categories of information about you: information you provide, information we collect automatically, and information we obtain from other sources.

We do not collect information about your racial or ethnic origin, political opinions or membership of any political association, religious or philosophical beliefs, trade-union membership, genetic data, or data concerning a person’s sex life or sexual orientation.

Information you provide

Registration and Courier information may include first name, surname, middle name, date of birth, residential address, contact phone number, e-mail, photo and video image, and identity document.

User generated content that you choose to upload while using our Services, such as comments, ratings, and reviews.

Information in correspondence you send to us may include chat messages, emails with any attachments, recordings of phone calls you make to us and the related metadata.

Information for promotions. From time to time, we may run promotional programs. If you wish to participate in such programs and receive bonuses, payments or other benefits, we may ask you to provide information such as your name, email, user ID, phone number, payment or banking information, address, social media account and image.

Information we collect automatically

Location information. We collect your location data for orders’ routing and assignment, to ensure the proper operation of our App, for security and anti-fraud purposes, and to comply with legal requirements.

Transaction information. We collect transaction information related to the Services, including the type of Services requested or provided, order details, amount charged, payment method, payment transaction information, and date and time the service was provided.

Usage information. We collect data about your use of our App, such as access dates and times, features or pages viewed, App crashes and other system activity. We may also collect and use for marketing purposes the data related to third-party services you used before interacting with the App.

Communications information. We enable users to communicate with each other and with us through the App. To facilitate this, we receive data about the time and date of the communications and the content. We may also use this data to provide support to other users or our clients, for security purposes, to resolve disputes between users, to improve our Services, and for analytical purposes (for example, to evaluate and improve the effectiveness of the Site).

Device information. We collect information about the device you use to access the App, such as your device name, brand and model, user agent, IP address, mobile carrier, network type, time zone settings, language settings, advertising identifiers, browser type, operating system and its version, screen parameters, battery state, and installed applications that can be used for authentication and anti-fraud purposes. We may also collect mobile sensor data, such as speed, direction, altitude, acceleration, deceleration, and other technical data.

Cookies and tracking technologies. We collect information through the use of cookies, pixels, tags and other similar tracking technologies ("cookies").

Information we obtain from other sources

Subcontractors and Partners. We may receive data about users from our subcontractors, partners and other InDrive products and services.

State authorities. We may receive information about users from law enforcement agencies and other government authorities as required or authorized by law.

Other users or third parties. Other Users and third parties may provide us with information about you, including through customer service or in connection with claims or disputes. We retain and use such information only if we could lawfully obtain it from you. We will take appropriate action as is reasonable under the circumstances to inform you of the receipt of such information.

How we use your information

We use the personal information for the following purposes:

1. To enable you to use InDrive.Delivery

• creating and maintaining your account, settings and preferences;
• calculating prices and making payments;
• providing the ability to exchange messages between users;
• providing support for users;
• sending non-marketing messages about the Services;
• ensuring the availability, security and stability of our App, diagnosing, preventing and resolving technical and service problems;
• to prevent fraudulent, unsafe or harmful practices;
• complying with legal requirements related to the Services and how you use them.

Legal basis: performance of our contract with you, the necessity to comply with our legal obligations, and our legitimate interest to make InDrive.Delivery a safe space. In some countries, we may use this information on the basis of your consent.

2. To improve and develop features and products

• perform testing, research, data analysis, development and machine learning;
• collect your feedback;
• developing new products, features and services.

Legal basis: our legitimate interest to give you and our clients the best InDrive.Delivery user experience. In some countries, we may use this information on the basis of your consent.

3. To promote InDrive.Delivery and Services

• send you marketing emails, text messages, push notifications, in-app messages and advertisements;
• provide you with personalized content and advertising on our App, and on third-party platforms;
• organize contests, events, and other promotions.

Legal basis: our legitimate interest in promoting InDrive.Delivery. In some countries, we may use this information on the basis of your consent.

4. To protect rights and comply with legal requirements

• comply with license or permit requirements, and any other applicable laws and regulations;
• respond to law enforcement requests, government inquiries, subpoenas, court orders, and legal claims;
• protect the rights and interests of the inDrive group, our users, or the public.

Legal basis: necessity to comply with our legal obligations and our legitimate interests.

5. Automated decision-making

We may use personal information to make automated decisions relating to your use of our Services:

• selecting the most appropriate location or order for you;
• detecting users who engage in fraudulent, unsafe or harmful practices.

Where required by law, actions (including deactivation) based on such processing occur only after human review and/or the possibility to appeal. To object to a decision resulting from these processes, please contact us at idd-support@indriver.com.

How we share your information

With service providers. We may share your personal information for business purposes with providers of the following services:

• payment processing and transaction fulfillment;
• user and technical support;
• background checks, identity verification;
• insurance;
• cloud storage;
• content delivery, in-app messaging, in-app calling, push notifications;
• anti-fraud;
• advertising, marketing, and analytics;
• research and surveys;
• payment of bonuses and provision of other benefits related to our promotions;
• consultants, lawyers, accountants, auditors, and other professional services;
• social media services in connection with our use of their functionality in the App.

Within the corporate group. We may share your information with a parent, subsidiary, or an affiliate of our corporate group as part of our global operations.

In connection with a business transfer. We may transfer personal information in connection with a substantial corporate transaction in which personal information is among the assets to be transferred.

For legal reasons. We may disclose your personal information when it is necessary to protect rights and comply with legal obligations.

With your consent. We may share your personal information for other purposes pursuant to your consent or at your direction.

When it is depersonalized. We may share aggregated or otherwise anonymized information which is no longer personally identifying.

Cross border data transfers

To support our global operations, we may share your information with members of inDrive corporate group and other entities outside of your country of residence as described in the section “How we share your information”. We do so for the performance of our contract with you, or based on consent, adequacy decisions for relevant countries, or other transfer mechanisms and appropriate safeguards under applicable law.

We will take reasonable steps to ensure that any overseas recipient deals with your personal information in a manner consistent with how we deal with it.

Your rights and choices

Accessing, receiving and updating your information. You may access, review and update your information either in your account settings in the app or by contacting us: idd-support@indriver.com. You may also request a copy of all information on you that we process. You may receive your data in a structured, commonly used and machine-readable format to the extent such data has been processed by automated means.

Sharing location information. Your device may have controls that determine what information we collect. For example, you can prevent your device from sharing location information through your device’s system settings.

Objections and withdrawal of consent. You have the right to object to us processing your information where processing is based on our legitimate interests. You can also withdraw consent to processing at any time where processing is based on your consent. In particular, you may exercise these rights by:

• Opting out of push notifications. You can opt out of receiving push notifications through your device settings or through the app settings. Not receiving push notifications may affect your use of Services (for example, you will not receive notification that you received a new order).
• Unsubscribing from marketing emails and messages. You can opt out of marketing emails and messages by using the “unsubscribe” link or the mechanism noted in such emails and messages.
• Opting out of marketing calls. You can opt out of receiving marketing calls during a call or by contacting us at idd-support@indriver.com.
• Managing cookies. You can delete cookies and modify your cookie settings in your web browser settings.

Do Not Track. Some browsers transmit “do-not-track” signals to websites. Because of differences in how browsers incorporate this feature, we currently do not take action in response to these signals.

Deleting your account and data. You can delete your account through the app settings or request the deletion of your account and your data by contacting us at idd-support@indriver.com. You may be asked to verify your account and identity. We will not be able to delete your account if there is an unsettled debt or an unresolved issue related to your account (for example, an unresolved complaint). We may retain certain information after your account is deleted provided there is a legitimate basis for such retention (see section “How we store your information”).

Submitting questions or complaints. We are happy to answer any questions you have about this policy or how we process your data. You can also send us any complaints about our processing of your personal data by contacting us at idd-support@indriver.com. We will respond to your request in accordance with applicable law after proper verification.

Right to complain to the supervisory authority. Under local law, you may have the right to file a complaint with your local supervisory authority.

How we store your information

We keep your personal information for as long as necessary to provide the Services and for the other purposes set forth in this policy.

Retention periods vary depending on the type of data and the purposes for which we use the data.

When we process your data to provide the Service, we keep the data until your account is deleted. We may keep user data after your account is deleted in accordance with legal or other regulatory requirements or for the reasons set forth in this policy. If you violate the License Agreement or InDrive.Delivery or InDrive global policies, we will have a right to keep your data for as long as we may need to investigate the violation. We also keep data for the purpose of responding to any claims regarding the Services.

How we protect your information

We take reasonable and appropriate technical, legal, and organizational security measures to protect your personal information from any unauthorized action including but not limited to access, disclosure, alteration, or destruction leading to loss, theft, or misuse of your data.

We regularly review our security measures to consider available new technology and methods. Since absolute security does not exist either on or off the Internet, we cannot guarantee the absolute security of your information, especially against maliciously intended acts by third parties where the cost for the successful attack multiplies several times the value of the data possibly compromised. Nevertheless, we make commercially reasonable efforts to keep your information safe.

General disclosures

Protecting children. inDrive.Delivery is not directed to children (as defined in the local laws). Should we discover that we hold the personal information of a child we will use reasonable endeavors to delete this data and ensure that it is not further used or shared. If you believe a child has provided us with personal information, please contact us at idd-support@indriver.com.

Changes to this policy. This policy will be updated when we make changes to our practices, products, or services, when we change our management or corporate structure, and as necessary to comply with our legal obligations. We will indicate the last update date at the beginning of this policy.

Contacting us. If you have any questions or concerns about this policy, please contact us at idd-support@indriver.com.