United Kingdom & European Economic Area Notice

 

The information in this Notice for United Kingdom & European Economic Area Residents (“UK & EEA Notice”) supplements the information provided under the main Privacy Notice, and provides Users who reside in the United Kingdom (“UK”) or European Economic Area (“EEA”) additional information required to be disclosed under the General Data Protection Regulation (“GDPR”).

Users using the Via Services in the UK or the EEA should consult this document in addition to Via’s primary Privacy Notice. Please refer to the information in this UK & EEA Notice if there are any conflicts between the two. The terms used in this UK & EEA Notice have the same definitions provided in the Privacy Notice, unless they are expressly given a new definition here. The term “personal information" further refers to the term Personal Data, as defined below and under the GDPR.

As with the Privacy Notice, this UK & EEA Notice does not apply to instances in which Via serves as a processor or service provider to Enterprise Customers. Please refer to the Processor Notice to End Users section of our Privacy Notice for more details.

Depending on which Via Services you are using and your jurisdiction, there will be a different Via data controller responsible for determining the purpose and the means of processing in accordance with the GDPR:

 

 

The above-mentioned Via entity (or entities, as applicable) is the party (or are the parties) to turn to in case of any questions or requests regarding the processing of your personal information or our privacy notices, and the relevant entity (or entities) can be contacted at support@ridewithvia.com, or as set out in the Complaints and Inquiries section below.

1. Legal Bases for Processing Personal Data
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Our legal basis for processing information relating to an identified or identifiable natural person (“Personal Data”) will depend on the type of Personal Data and the specific context in which we collect and use it. The table below illustrates the categories of Personal Data we collect, provides examples of how we use Personal Data within each category, and describes the legal bases for our processing of each category of Personal Data. Additional details about our use of Personal Data can be found in the “How We Use Personal Information” section of the Privacy Notice.

In the table below, “Performance of a contract” refers to processing for the purpose of performance of our agreements with Users and Enterprise Customers, including our Terms of Use.

As described in the table, in certain circumstances, we may ask for your consent to collect and process Personal Data for the purposes described below. Where we rely on consent, you have the right to withdraw your consent at any time, in which case we will cease that collection and use of your Personal Data for the purpose for which you provided consent.

When we process Personal Data based on our legitimate interests, it is for the purpose of operating the Via Services, ensuring that the Via Services remain relevant and function well for each User, developing new and innovative services and features, and preventing fraud while promoting the safety and security of Users, Enterprise Customers, Via, our contractual counterparties, and the general public.

Note that we may process all categories of Personal Data for the purpose of complying with regulations or lawful requests, and for enforcing our terms, policies, and agreements. This processing is based on our legal obligations and/or legitimate interests, as appropriate.

 

2. Retention of Personal Data

We retain Personal Data about you for as long as necessary for the purposes and legal bases set out in this UK & EEA Notice, unless a longer period is required under applicable law or is needed to resolve disputes or protect our legal rights. In all cases, in addition to the purposes and legal bases, we consider the amount, nature and sensitivity of the personal data, as well as the potential risk of harm from unauthorized use or disclosure of your personal data.

3. Your Privacy Rights

Your rights with respect to your Personal Data are set forth in the “Your Rights” section of our main Privacy Notice and are subject to certain limitations under applicable laws.

You can exercise any of these rights by contacting us at support@ridewithvia.com.

Certain Via Apps may also have an in-app deletion function, which you may use to delete your account information. You can also use the cookie preference management tool on our Website to manage your preferences and opt out of any cookies. For details on unsubscribing from marketing communications or changing your communication preferences, please refer to the Privacy Notice.

We will comply with all applicable laws governing your requests. Please note that we may need to verify your identity before processing your request, which may require us to collect additional Personal Data from you. We may decline a request to exercise the rights listed above, consistent with applicable laws. Please also note that if your exercise of any of the rights limits our ability to process Personal Data, we may not be able to provide some or all portions of the Via Services to you going forward.

4. Complaints and Inquiries 

If you have any questions about this UK & EEA Notice, the information that we collect from you, or the Via Services, or if you have a complaint about our processing of your Personal Data, please contact us at the relevant address listed here.

Our data protection officer (“DPO”) is reachable at dpo@ridewithvia.com. Via takes all concerns about privacy and use of data very seriously, and we shall reply to you within one month of receiving a complaint to either (a) answer your request; or (b) request additional time to respond, setting out our reasons for doing so, extending our timeframe to respond to your request by two months.

You may also ask questions or lodge a formal complaint with your national data protection authority. The applicable Supervisory Authority for the Via Services in the UK is the Information Commissioner’s Office. For the Via Services in the EEA, please refer to the list of authorities here.

5. International Data Transfers

As noted in our Privacy Notice, if we transfer your Personal Data outside of the EEA or UK (whether it is transferred among our subsidiaries or affiliates or to the third parties identified in the Privacy Notice), we ensure compliance with all applicable legal requirements. That means that we may transfer Personal Data about you to countries that the European Commission or the United Kingdom Government has deemed to adequately safeguard such data. For transferring Personal Data from the EEA to all other countries, we rely on standard contractual clauses adopted by the European Commission, and for transfers from the UK to all other countries, we rely on the International Data Transfer Addendum to the European Commission Standard Contractual Clauses.

With respect to transfers of personal information from the European Union to the United States, we comply with the EU-U.S. Data Privacy Framework (“EU-U.S. DPF”) and the UK Extension to the EU-U.S. DPF, as set forth by the U.S. Department of Commerce (collectively, the “DPF”). Please see the “Cross-Border Transfers” section of our Privacy Notice for details about our compliance with the DPF. To learn more about the DPF program, and to view our certification in the DPF list of participants, please visit https://www.dataprivacyframework.gov/.

6. Updates to this UK & EEA Notice

We will update this UK & EEA Notice from time to time as the Via Services change and in accordance with applicable laws and regulations. When we make changes to this UK & EEA Notice, we will change the “Last Updated” date at the beginning of the notice. If we make significant changes, we will notify you through a pop-up notification on the Via Apps, Via Websites, or elsewhere in the Via Solution, or by other means, including email or a prominently posted notice at the beginning of this UK & EEA Notice. All changes shall be effective from the date of publication unless otherwise provided in the notification. We encourage you to review this UK & EEA Notice periodically. By using the Via Services after an update, you consent to the updated version of the UK & EEA Notice.