The information in this Notice for United Kingdom & European Economic Area Residents (“UK & EEA Notice”) is provided to help Users who reside in the United Kingdom (“UK”) or European Economic Area (“EEA”) understand their rights and to provide other information required under relevant laws.
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.
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, there will be a different Via data controller responsible for determining the purpose and the means of processing in accordance with the General Data Protection Regulation (“GDPR”):
| Riders, Drivers, and Delivery Users |
UK: Via Transportation UK Limited Via Technologies Europe B.V. will be a joint controller of the personal data collected by the UK-based and Germany-based Via entities. This includes any processing for the purposes of improving the Via Services. |
| Visitors | Via Technologies Europe B.V. and Via Transportation, Inc. |
| Enterprise Platform Users | The Via entity that you contracted with and either Via Transportation, Inc. or Remix Technologies LLC |
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
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 it. The table below illustrates the categories of Personal Data we collect, provides examples of how we use 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.
| Category of Personal Data | Purposes of Processing | Legal Bases for Processing |
|
User Account Information, as defined in the Privacy Notice, which may include but is not limited to: Note that the User Account Information collected differs based on the specific Via Services at issue and the type of User providing it. |
Setting up and managing User Accounts; providing the Via Services; personalizing the Via Services; improving the Via Services; facilitating safety, security, and fraud prevention; customer support; communications; compliance with regulations or lawful requests. | We conduct this processing pursuant to our legitimate interests in providing the Via Services to you and other Users, ensuring that the Via Services are relevant and well-functioning for each User, and preventing fraud and promoting the safety and security of Users, Enterprise Customers, Via, our contractual counterparties, and the general public. We also conduct this processing to fulfill our obligations to Users and Enterprise Customers under our Terms of Use or other agreements, as well as under applicable laws and regulations. In certain circumstances, we may also ask for your consent to collect personal information in this category for the purpose of providing or improving the Via Services. |
| Your Communications With Us, as defined in the Privacy Notice, which may include but is not limited to: - Content of your messages or telephone calls to us - Your rating of your experience using the Via Services - Telephone call recordings - Information apparent from your communications (e.g., the email address from which you contact us) |
Providing customer support; responding to your communications; providing the Via Services; improving the Via Services; facilitating safety, security, and fraud prevention; compliance with regulations or lawful requests. |
We conduct this processing pursuant to our legitimate interests in providing the Via Services to you and other Users, ensuring that the Via Services are relevant and well-functioning for each User, responding to your inquiries and feedback, and preventing fraud and promoting the safety and security of Users, Enterprise Customers, Via, our contractual counterparties, and the general public. We also conduct this processing to fulfill our obligations to Users and Enterprise Customers under our Terms of Use or other agreements, as well as under applicable laws and regulations. |
| Location Information, as defined in the Privacy Notice | Providing the Via Services; personalizing the Via Services; improving the Via Services; facilitating safety, security, and fraud prevention; customer support; communications; compliance with regulations or lawful requests. | We conduct this processing pursuant to our legitimate interests in providing the Via Services to you and other Users, ensuring that the Via Services are relevant and well-functioning for each User, and preventing fraud and promoting the safety and security of Users, Enterprise Customers, Via, our contractual counterparties, and the general public. We also conduct this processing to fulfill our obligations to Users and Enterprise Customers under our Terms of Use or other agreements, as well as under applicable laws and regulations. |
|
Usage Information, as defined in the Privacy Notice, which may include but is not limited to: - Details about any transactions made through your User Account |
Providing the Via Services; personalizing the Via Services; improving the Via Services; facilitating safety, security, and fraud prevention; customer support; communications; compliance with regulations or lawful requests. | We conduct this processing pursuant to our legitimate interests in providing the Via Services to you and other Users, ensuring that the Via Services are relevant and well-functioning for each User, developing new and innovative services and features, and preventing fraud and promoting the safety and security of Users, Enterprise Customers, Via, our contractual counterparties, and the general public. We also conduct this processing to fulfill our obligations to Users and Enterprise Customers under our Terms of Use or other agreements. In certain circumstances, we may also ask for your consent to collect personal information in this category for the purpose of providing or improving the Via Services. |
| Device Information, as defined in the Privacy Notice, which may include but is not limited to: - IP address - Operating system and browser details - Information about mobile devices used to access the Via Services |
Providing the Via Services; personalizing the Via Services; improving the Via Services; facilitating safety, security, and fraud prevention; customer support. |
We conduct this processing pursuant to our legitimate interests in providing the Via Services to you and other Users, ensuring that the Via Services are relevant and well-functioning for each User, developing new and innovative services and features, and preventing fraud and promoting the safety and security of Users, Enterprise Customers, Via, our contractual counterparties, and the general public. We also conduct this processing to fulfill our obligations to Users and Enterprise Customers under our Terms of Use or other agreements. |
| Survey Information, as defined in the Privacy Notice, which may include but is not limited to contact information and demographic information | Enabling you to participate in a survey, quiz, contest, or promotion; improving the Via Services; personalizing the Via Services; facilitating safety, security, and fraud prevention. |
We conduct this processing pursuant to our legitimate interests in providing relevant and well-functioning services and developing new and innovative services and features. In certain circumstances, we may also ask for your consent to collect personal information in this category. |
| Metadata from communications between Riders and Drivers, including the date, time, and phone numbers involved in calls made through our third-party vendor | Customer support; facilitating safety, security, and fraud prevention; improving the services; compliance with regulations or lawful requests. | We conduct this processing pursuant to our legitimate interests in providing relevant and well-functioning services and preventing fraud and promoting the safety and security of Users, Enterprise Customers, Via, our contractual counterparties, and the general public. We also conduct this processing to fulfill our obligations to Users and Enterprise Customers under our Terms of Use or other agreements. |
| Visitor Contact Information, as defined in the Privacy Notice, which may include but is not limited to: - Name - Email address - Mailing address - Phone number - Occupational and employer information |
Communicating with you about the Via Services; taking steps to fulfill your requests prior to entering into a contractual relationship; improving the services; understanding the interests and attributes of current or prospective Enterprise Customers; compliance with regulations or lawful requests. | We conduct this processing pursuant to our legitimate interests in providing the Via Services to you and responding to your inquiries and feedback. We may also ask for your consent to collect personal information in this category for the purpose of providing or improving the Via Services. |
| Analytics data, including information collected through cookies and other tracking technologies, as described in the Cookie Notice | Please see our Cookie Notice for details about how we use cookies. | We conduct this processing pursuant to our legitimate interests in providing the Via Services to you and ensuring that the Via Services are relevant and well-functioning, or with your consent. We also conduct this processing to fulfill our obligations to Users and Enterprise Customers under our Terms of Use or other agreements. |
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
You have the following rights in relation to your Personal Data (subject to certain limitations under applicable laws):
- Access: The right to access and obtain a copy of your Personal Data, as well as information relating to its processing.
- Correction and Update: The right to correct or update any Personal Data that is inaccurate or incomplete. You control your account information and settings and you may update your User Account information and communication preferences at any time.
- Restriction of Processing: The right to require us to limit the purposes for which we process your Personal Data if the continued processing of the Personal Data in this way is not justified, such as where the accuracy of the personal data is contested by you.
- Erasure: The right to request the deletion or erasure of Personal Data about you if the continued processing of that personal information is not justified.
- Portability: The right to obtain a copy of Personal Data about you in an easily accessible format and the right to transmit that personal data to another controller.
- Objection to Processing: You also have the right to object to any processing of your Personal Data based on our legitimate interests where there are grounds relating to your particular situation. There may be compelling reasons for continuing to process your Personal Data, and we will assess and inform you if that is the case.
Where we rely on your consent for processing of your personal data, you also have the right to withdraw your consent to such processing, subject to certain limitations at law. You can withdraw your consent by emailing support@ridewithvia.com. In the case of mobile device location services, you can change your location preferences at any time by managing your device settings.
You can exercise any of the rights listed above by contacting us at support@ridewithvia.com. 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 listed above 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.
For details on unsubscribing from marketing communications or changing your communication preferences, please refer to the Privacy Notice.
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 more 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.