Effective Date: January 2023

This Privacy Notice explains how VshSafar (Pvt.) Ltd.  and/or its Affiliates (collectively “VshSafar”, “we” or “us”) collects and uses Personal Data. The Notice applies to all users of VshSafar’s mobile applications, websites, call-centre or technology (collectively, the “VshSafar Platform”), users of any other products and services we provide, and when users interact or communicate with us (all collectively, the “Services”). 

By accessing or using the Services, you confirm that you have read this Privacy Notice in full and understand that information collected by VshSafar in accordance with this Privacy Notice may be used in accordance with Applicable Laws, this Privacy Notice and our End User or Captain Terms of Use.

Unless stated otherwise, VshSafar (Pvt.) Ltd. is the data controller for the Personal Data collected in connection with the use of VshSafar’s Services.

1. Scope and Application

1. 2. Collection of Information
2. 3. Use of Personal Data
3. 4. Sharing of Personal Data
4. 5. Automated decision taking
5. 6. Storage of Personal Data
6. 7. Your Choices
7. 8. Security Precautions
8. 9. Cookies
9. 10. Guest Users
10. 11. Suppliers
11. 12. Visitors
12. 13. Changes to this Privacy Notice
13. 14. Contact Us

1. Scope and Application

This Privacy Notice applies to all individuals anywhere in the world who access or use our Services. It specifically applies to:

• Car Users: individuals that book a trip on a VshSafar CAR.

• Captains: individuals that provide (or submit the application to provide) transportation of people or goods, whether individually or through partner transportation companies.

• Delivery Recipients: individuals that purchase or receive a Product sold by a Merchant Partner, including via VshSafar Food and Shops.

• Express Users: companies that rely on VshSafar Express solutions for the delivery of goods sold through platforms other than the VshSafar Platform.

• OA Users: individuals that request the pick up or receive products, other than Express Users.

• PAY Users: individuals that make use of PAY services such as, sending or receiving money through VshSafar PAY (including to purchase goods and services from E-Commerce Partners) and paying for utility bills.

• Riders : individuals that request or receive transportation, including those that receive transportation requested by another individual.

• Super App Users : individuals that purchase services from a Merchant Partner through the VshSafar Platform, such as home cleaning services.

(each referred to in this Privacy Notice as “you” or "Data Subject"as the context requires).

Across this Notice, we will be using some important definitions:

• Affiliates means: (i) any entity where VshSafar (Pvt.) Ltd., directly or indirectly, through one or more intermediaries, holds at least 25% of the equity or 25% of the voting rights; and (ii) any subsidiary or affiliate of such entity in (i). It also includes our legal representatives, administrators, successors-in-interest and permitted assigns.
• Applicable Law means any law that applies to our processing of your Personal Data, whether by virtue of offering Services to you, monitoring your behaviour online (such as by using Cookies), your using of our Services or the provision of your services to us.
• ECommerce Partners: a third party that enable Captains and/or End Users to pay for goods or services on their websites using VshSafar Pay technology.
• End Users refers to Riders, Delivery Recipients, OA Recipients, Super App Users, Bike Users and PAY Users.
• Personal Data is any data or information that relates to an individual and which could, of itself or in combination with other data or information, identify who an individual is.
• Products are any goods or services displayed on the VshSafar Platform.
• Merchant Partner is a third party that makes available the delivery of goods, restaurant meals or services through the VshSafar Platform.
• Process or Processing means the collection, storage, use or transfer of Personal Data.
• Terms of Use means the Customer or Captain Terms of Use.

2. Collection of Information

Depending on the Services you are accessing or using, we collect and use:

A. Information that you provide directly to us;
B. Information about the use of your account and our Services;
C. Information obtained from other sources and third parties, which may include information about you.

A. Information You Provide to Us

Whether you are an End User or a Captain, you are solely responsible for the accuracy of the information you provide, and VshSafar will only modify or update your Personal Data upon your request or when you modify your account details.

When we collect sufficient Personal Data from you in order to open an account for you, we will generate an account number known as your “VshSafar Account ID”. The VshSafar Account ID is unique to you and is used by us to identify you across our various Services and geographies.

Please note that if you choose not to provide us with some of this Personal Data, or request that we erase some or all of it, we may not be able to provide you with our Services at all, or provide it to the same standard we can if we are using that Personal Data.

B. Information We Collect Through use of Our Services

End Users and Captains

When you access or use our Services, either as an End User or Captain, we collect information, some of which will constitute Personal Data. In some cases, we collect this data through cookies, pixels, tags, and similar tracking technologies that create and maintain unique identifiers. Such information may include your:

• mobile network information;
• mobile operating system;
• mobile application crash reports;
• mobile application features and applications used;
• time zone setting;
• device location;
• IP address;
• device information, including the type of mobile device you use, a unique device identifier (for example, your device’s IMEI number, the MAC address of the device’s wireless network interface, installed applications, or the mobile phone number used by the device);
• SMS data;
• Transaction-related information;
• Information on safety-related incidents;
• browsing history information (i.e. any third party services you accessed or used prior to using our Services); and
• registration history information.
  
  

If you are an End User we may also collect:

• details of the specific Service you have requested;
• specific requirements in respect of an order you make via our Services;
• Captain feedback you choose to provide;
• your specific location at the time you are accessing or using our Services;
• the time and date of your booking of the Service, either at that time or at a time in the future;
• your booked or actual destination;
• your trip route;
• the third party supplier you have used, for example which Merchant Partner you have placed an order from; and
• the Personal Data of individuals on whose behalf you access or use our Services, for example, when you book a ride for others or request the delivery of a Product to or from a friend.
  
  

If you are a Captain we also collect:

• any End User feedback you choose to provide;
• details of any journeys you have made or services you have provided;
• your trip route;
• the time and date of any bookings you accepted, rejected or cancelled.

We also use GPS technology to determine your current location. For Captains, GPS technology may be used when the VshSafar application is running in the background and foreground, whether the Captain is online or offline. For End Users, GPS technology will only be used when the VshSafar application is active in the foreground of your phone’s applications or during a Trip.

Some of our location-enabled Services require your Personal Data for the feature to work. By accepting the terms of this Privacy Notice you are agreeing to the use of GPS technology when relevant to the use of our Services. Use of GPS is a setting that you can switch on and off from your phone device settings at any time.

C. Information We Collect From Other Sources

End Users and Captains

We may also receive information, including Personal Data, from other sources and combine that either with Personal Data we receive from you or collect through our Services. For example:

• We may receive information from your employer (or similar entity) if your employer (or similar entity) participates in any of our enterprise/corporate solutions
• If you choose to link, create, or log in to your VshSafar account with a payment provider or social media service (e.g., Facebook), or if you engage with a separate app or website that uses our API (or whose API we use), we may receive information about you or your connections from that site or app;
• We may get information from our Affiliates on whether you have been blocked from providing services on or blocked from making use of the Affiliates’ services; and
• We may obtain Personal Data from third parties who help us verify an individual’s identity and background information for legal, regulatory, anti-money laundering, safety, and security purposes. This can include screening against sanctions lists, lists of politically exposed persons and relatives/close associates of such persons, and adverse media.
  
  

If you are an End User we may also:

• collect information about you from your employer, if your employer uses one of our enterprise solutions; and
• receive ratings by Captains after they have provided services to you.
  
  

If you are a Captain we may also:

• receive ratings by End Users after you have provided services to them;
• if you also interact with our Services in another capacity, for instance if you are both an End User and a Captain or if you make use services by one or more of our Affiliates, we may combine or associate that information;
• receive information relating to you from a third party company with which we contract, if you are a Captain that is employed by or contracted with a third party company;
• receive information from your insurance, vehicle, or financial services providers;
• obtain any additional information on you, as required, from publicly available sources or governmental authorities.

3. Use of Personal Data

End Users and Captains

We may use Personal Data collected in the manners described above to:

• Provide, maintain, and improve our Services
• Perform internal administration and operations, including to conduct data analysis, testing, and research; to monitor and analyze usage and activity trends; and to troubleshoot software bugs and operational problems
• Send or facilitate communications (i) between End Users and Captains, such as estimated times of arrival (ETAs), or (ii) at your direction, between you and a contact of yours in connection with your use of certain features, such as referrals or invites;
• Send you communications to you, including administrative or Service-related messages, receipts and other communications we think will be of interest to you, including information about existing and/or new products, services, promotions, news, and events of VshSafar and other companies, where permissible and according to Applicable Laws;
• Process contest, sweepstake, or other promotion entries and fulfill any related awards;
• Allow you to participate in interactive features of our Services;
• Keep our Services safe and secure, including screening Captains and End Users before enabling their use of our Services and at subsequent intervals, including through reviews of background checks, where permitted by law, to help prevent use of our services by unsafe Captains and/or End Users;
• Prevent, detect, and combat fraud or unsafe activities, including by using device, location, profile, usage, and other data;
• Personalize and improve the Services, including to provide or recommend features, content, social connections, referrals, and advertisements;
• Using End User and Captain ratings and feedback to encourage compliance with VshSafar’s Terms of Use and as grounds for deactivating Captains with low ratings or who otherwise violated such guidelines in certain countries;
• Locate you if you use the alert button within the VshSafar mobile application; and
• To ask you about your experience using our Services, including about a particular Captain.
  
  

Captains only

We may use Personal Data collected in the manners described above to:

• In certain regions, using information derived from the Captain’s license photos, and other photos submitted to VshSafar, for safety and security purposes. This includes a real-time ID feature, which prompts you to share a selfie before going online or while online to help ensure that the individual using our app matches the Captain account we have on file. This also includes comparing photographs that we have on file against photographs (i) of other users to prevent identity-borrowing, and (ii) from public databases to verify user identity; and
• Offer, obtain, provide, or facilitate insurance, vehicle, invoicing or financing solutions.

4. Sharing of Personal Data

Depending upon the purposes for which we have collected your Personal Data, we may share your Personal Data:

End Users and Captains

We may share your Personal Data:

• With VshSafar Affiliates;
• With third parties that we use to carry out work on our behalf or to perform a contract we enter into with them, including:
  • Google, in connection with the use of Google Maps in VshSafar Platform (see Google's privacy policy for information on their collection and use of data).
  • social media companies, including Facebook, in connection with VshSafar's use of their tools in the VshSafar Platform (see Facebook's privacy policy for information on their collection and use of data);
  • vendors who help us verify identity, background information, or who screen users in connection with sanctions, anti-money laundering, fraud or know-your-customer requirements. In some cases, these service providers may retain identity documents that are suspected to be fraudulent for the purpose of identifying fraud in the future;
  • cloud storage providers;
  • payment processors and facilitators;
  • marketing partners and marketing platform providers, including social media advertising services, advertising networks, third-party data providers, and other service providers that help us understand you better as a user and measure advertising effectiveness;
  • research partners, including those performing surveys or research projects in partnership with VshSafar or on VshSafar's behalf;
  • vendors that assist VshSafar to enhance the safety and security of our Services;
  • consultants, lawyers, accountants, and other professional service providers;
  • airports, including when required by airport authorities as a condition of operating on airport property;
  • telecommunications companies, utility providers and other third parties to offer to you and enable you to buy prepaid services or pay for postpaid services you obtain from them;
  • e-Commerce providers to enable to you to purchase goods and services from them through VshSafar PAY.
  • financing partners; and
  • financial institutions, such as banks we partner with to offer joint products.
  
  
• With third parties where you choose to pay bills as part of our VshSafar Pay services;
• With financial institutions that we have partnered with to provide the VshSafar Pay service;
• With third parties to market their products or services to you if you have agreed to receive promotional updates;
• If we otherwise notify you and you consent to the sharing;
• With third parties in an aggregated and/or anonymized form which cannot reasonably be used to identify you;
• With law enforcement officials, financial regulators, anti money laundering agencies, government authorities, public health officials, competent authorities or other third parties: (i) to enforce or apply our Terms of Use; (ii) to investigate potential breaches of these terms or applicable laws or if we believe your actions are inconsistent with our Terms of Use; (iii) to protect the rights, property, or safety of VshSafar or others; or (iv) if we believe disclosure is in accordance with, or is otherwise required by any applicable law, regulation, operating license or agreement, legal process or governmental requests, or where the disclosure is otherwise appropriate due to safety or similar concern;
• With a claims processor or an insurer to provide any necessary information (including your contact information) if there is a complaint, dispute or conflict, which may include an accident, involving you and another party and such information or data is necessary to resolve the complaint, dispute or conflict; and
• With third parties 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.

End Users only

We may share your Personal Data:

• At your request, such as when you agree to share your ETA and location with a friend;
• With Captains, to enable them to provide the Services you request. For example, we share your name and pickup and/or drop-off locations with Captains;
• With Merchant Partners and/or their point-of-sale providers for order fulfillment, delivery, communications and marketing purposes. In some cases, including when the Merchant Partner is self-delivering the Order to you, we will provide your information to that Merchant Partner in a similar manner as if you had placed the order for Services directly with the Merchant Partner;
• With third parties to provide you with a service you requested, including bill payment services and services that you may have requested through a partnership or promotional offering made by a third party or us;
• With third parties with whom you choose to let us share your Personal Data, including other applications or websites that integrate with our API or Services, or those with an API or service with which we integrate;
• With Hala in the manner identified in this Privacy Notice; or
• With your employer (or similar entity) if your employer participates in any of our enterprise/corporate solutions.
  
  

Captains only

• With End Users, to enable them to identify you and your vehicle;
• With any Merchant which you are collecting an order on behalf of an End User;
• With your employer or the third-party transportation company your Captain account is associated with; and
• With insurance companies or providers of fleet financing solutions whose product offerings we consider may be of interest to you.

5. Automated decision taking

We use personal data to make automated decisions relating to use of our Services, such as to:

• Determine Captains and End Users ratings, and deactivating where there are low ratings;
• Match available Captains to End Users requesting services based on availability, proximity, and other factors;
• Enable dynamic pricing, in which the price of a ride or the delivery fee is determined based on constantly varying factors such as the estimated time and distance, the predicted route, estimated traffic, and the number of Captains and End Users using VshSafar at a given moment; and
• Flag Captains and/or End Users who are identified as having engaged in fraud, unsafe activity, or other activities that may harm VshSafar and/or others.

VshSafar performs the above activities on the grounds that they are necessary to fulfill our obligations to users under our Terms of Use or other agreements with users, or on the grounds that they are necessary for purposes of the legitimate interests of VshSafar, its users and others.

6. Storage of Personal Data

We will store and retain your Personal Data for the period of time necessary for the purpose for which the data has been collected, unless the nature of the purpose changes in which case the retention period may be extended or shortened.

Apart from the purposes for which we collect your Personal Data, we also store and retain this Personal Data to preserve the integrity of our databases, to carry out on-going Services on your behalf, for research, analytics and statistics purposes and to ensure compliance with applicable laws and regulations.

Following an account deletion request (where warranted in accordance with the data subject rights referred to below), we will erase or archive from active use the Personal Data of the individual to which the requirement or request relates, unless we are required to retain it due to legal or regulatory requirements, for purposes of safety, security, and fraud prevention, or because of an issue relating to your account such as an outstanding credit or an unresolved claim or dispute.

7. Your Choices

1. Device permissions

Most mobile device platforms (iOS, Android, etc.) have defined certain types of device data that apps cannot access without the device owner’s permission. Different platforms have different methods for how that permission can be obtained. Please check the available settings on your device or check with your provider.

2. Marketing and Opting Out

In some countries we cannot provide you with any direct marketing communications unless we have obtained your express consent to do so in advance.

In all cases, VshSafar provides End Users and Captains the opportunity to opt-out of receiving direct marketing communications from us and our partners:

• in any direct email marketing communication that you receive from us; and
• for End Users, from the ‘Settings’ menu in the VshSafar application.
  
  

3. Data Subject Rights

If you would like VshSafar to correct personal data VshSafar holds about you, please read here. This enables you to have any incomplete or inaccurate information VshSafar holds about you corrected.

If you decide to delete your account, follow the steps mentioned here. Please note that if you are a Captain, additional steps may be required to give effect to this request.

Depending upon which country you are in at the time that we collect and use your Personal Data and the Service that you make use of you may have some or all of the following rights under applicable law:

• To request access to your data, including your profile data and trip or order history (commonly known as a "data subject access request"). If the information you request reveals personal data about a third party, we will: (i) seek that individual's consent before responding to your request, (ii) consider if it is otherwise reasonable to provide it to you; or (iii) we will redact third parties' personal data before responding. If we are unable to provide you with access to your personal data because disclosure would infringe the rights and freedoms of third parties, we will notify you of this decision.
• To request erasure of your Personal Data. This enables you to ask VshSafar to erase Personal Data where:
  • your Personal Data is no longer needed for the purposes for which it was collected;
  • the sole legal ground for processing was your consent and you have withdrawn it;
  • you have objected to processing of your Personal Data on the legal grounds relating to your particular situation, and VshSafar cannot prove that there are overriding legitimate interests for processing;
  • your Personal Data were processed unlawfully; or
  • your Personal Data must be erased in order to comply with legal requirements.

Before requesting to delete an account, you are required to complete/cancel and active or schedule orders or bookings, cancel any VshSafar Plus or Bike subscriptions and empty your VshSafar PAY wallet. If you are the end user of an enterprise/corporate account, we may be unable to process your deletion request if there are outstanding payments for that enterprise account.

After we receive your erasure request, you will be logged out of your VshSafar account. We will process your request within 90 days. If you log in your VshSafar Account during these 90 days, your deletion account will be cancelled and your account will remain unchanged.

VshSafar may be required to retain some data in line with legal or regulatory requirements, for purposes of safety, security, and fraud prevention, or because of an issue relating to your account such as an outstanding credit or an unresolved claim or dispute.

• To object to us processing of your Personal Data where VshSafar is relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground.

• To request us to restrict our processing of your Personal Data where:

  • you consider that our processing of your Personal Data is inaccurate;
  • you consider that the processing is unlawful and you oppose the erasure of your Personal Data and you require the restriction of the processing instead;
  • we no longer need the Personal Data for the purposes of the processing but the Personal Data is required by you for the establishment, exercise or defence of a legal claim; or
  • where you require verification that processing on the legitimate interests of VshSafar override your interests.

• To revoke your consent, where we have expressly asked for your consent as a legal basis to process your Personal Data. The revocation of your consent will not affect the lawfulness of the processing based on your prior consent.

Depending on your location or the version of the VshSafar application that you are using, you may exercise these rights through the Settings menu in the VshSafar app or by contacting us here.

We will contact you for additional information if we are unable to verify your identity, the scope of your request is unclear or does not provide sufficient information for us to conduct a search (for example, this will be the case if you request “all information about me”). Once we have all the information, we need to locate your personal data, we will begin processing your request.

Applicable law may allow or require us to refuse to act on your request, or we may have destroyed, erased, or made your personal data anonymous in accordance with our record retention obligations and practices. If we determine that your request does not have a legal basis, we reserve the right to not further process your request and we will inform you of this decision.

In addition, depending on your location, you may have the right to file a complaint relating to our handling of your Personal Data with the data protection authority in your country.

8. Security Precautions

Your VshSafar profile is password-protected so that only you and authorized VshSafar employees or service providers ( “Authorised Personnel” ) have access to your account information. VshSafar’s Authorised Personnel will never proactively reach out to you and ask for any personal account information, including your password.

VshSafar makes every effort to ensure that your Personal Data is secure on its systems. VshSafar has colleagues dedicated to maintaining adherence to this Privacy Notice and other privacy initiatives, periodically reviewing security of our Services and making sure that all VshSafar colleagues are aware of our security practices. Unfortunately, no data transmission over the Internet can be guaranteed to be 100% secure. As a result, VshSafar cannot guarantee the security of any Personal Data you transmit to us, and you do so at your own risk. If you have any further questions on this issue, refer to the Terms of Use. To the extent permitted by Applicable Law, VshSafar expressly disclaims any liability, and you hereby waive any claims, and indemnify us for any claims that may be brought by third parties who access or use our Services via your account, that may arise should any other individuals obtain the Personal Data VshSafar collects about you or third parties who access or use our Services via your account.

9. Cookies

Cookies are small text files that are stored on browsers or devices by websites, apps, online media, and advertisements. We use cookies and similar technologies for purposes such as:

• distinguishing you from other users of on the VshSafar Platform;
• remembering your preferences and settings
• understanding the online behaviors and interests of people who interact with our Services, including determining the popularity of content and analysing site traffic and trends
• improving our VshSafar Platform and the Services we provide

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.

10. Guest Users

We consider you a Guest User if you receive trips or deliveries but are not the owner of an account with VshSafar, such as when:

• You purchase physical products from third parties (including restaurants, ecommerce platforms or other merchants) that use the VshSafar Platform for the delivery of the physical products to you.
• You request a trip or delivery via partner websites or apps such as ride-hailing aggregators.
• Your location is marked as a pickup or drop off location for our Order Anything services.
• A trip or delivery is arranged by another account owner.
• When a VshSafar User transfers money to you.

Guest User personal data may be associated with, and accessible by, the owner of the VshSafar account.

In these cases, your personal data is used and may be shared with third parties: (i) to provide such trips, deliveries or to enable such transfers; and (ii) for purposes of safety and security, customer support, research and development, enabling communication between users, and in connection with legal proceedings and requirements.

11. Suppliers

We consider you as a Supplier if you are an individual (not Captains) that provide services to VshSafar, either in their own capacity, or on behalf of an organization as a member or employee of that organization.

If you are a Supplier or work for a Supplier, we collect Personal Data when you, or the business you represent provides, or seeks to provide us with, services; or otherwise communicate with us.

The Personal Data collected during may include:

• your name;
• your email address;
• your phone number;
• your postal address;
• passport or national identification number;
• bank information where payment for Services will be made;
• information on shareholders, principal officers, financial history, references, and ultimate beneficial owners; and
• other information which we reasonably require or that you choose to provide.

We may use Personal Data collected in the manners described above to:

• To contact you with regards to the provision of your services to us; and
• To facilitate payments to you; and
• To consider our potential or current relationship with your business.

If you are a Supplier we will be relying on third parties who help us verify identity and background information for legal, regulatory, anti-money laundering, sanctions and security purposes. This can include screening against sanctions lists, lists of politically exposed persons and relatives/close associates of such persons, and adverse media.

Please note that if you choose not to provide us with some of this Personal Data, or request that we erase some or all of it, we may not be able to engage you or continue to engage you to provide services to us.

12. Visitors

We consider you as a Visitor if you visit VshSafar premises other than as a VshSafar employee or individual contractor. When visiting VshSafar premises, you may be asked to input personal information and register as a visitor using a visitor management system. During this registration, you may be also asked to sign a non-disclosure agreement.

This information is used to ensure the safety of individuals within VshSafar premises and to safeguard information that is shared with you during your visit at VshSafar premises.

13. Changes to this Privacy Notice

We may change this Privacy Notice from time to time. If we make significant changes in the way we treat your Personal Data, or to the Privacy Notice, we will provide you notice through the Services or by some other means, such as email or a push notification.

To the extent permitted by Applicable Law, your continued use of the Services after such notice constitutes your consent to the changes to the extent permitted by law.

We encourage you to periodically review this Privacy Notice for the latest information on our privacy practices.