Privacy Policy - ONDE EAST FZCO

This Privacy Policy (“Policy”) extends to a set of web products and mobile apps created and owned by ONDE EAST FZCO, a company incorporated and acting under the laws of the United Arab Emirates. CBLS No 12080185, Legal Type: Free Zone Company, Est. Date: 26/04/2023, Legal Address: Premises Number: 29706 - 001, IFZA Business Park, Building A1, Dubai Digital Park, Dubai Silicon Oasis, Dubai, United Arab Emirates (“Onde”, “we”, “our”) and users of our Service and visitors of our Website (“you”)

Onde owns a software platform that includes ride-hailing applications or websites such as “My Hub”, “Web application”, “Operator application”, “Onde Light”, “Driver App”, “Customer App” and other applications to provide our services (collectively “Service”). Our main website is https://onde.app (“Website”).

The Policy outlines:

what information and personal data (“PD”) we may collect from you via the Service/Website;
how it will be used, disclosed, and shared with third parties;
the use of cookies;
other related issues.

Onde is the controller and the processor of PD. Terms that aren’t defined in the Policy shall have the same meaning as in the General Terms and Conditions (“T&C”) placed on our Website.

To use the Service, you shall consent to the Policy and the T&C. You agree to the Policy when you indicate your consent by clicking 'I Agree' when prompted. To use the Website, you shall consent to essential cookies without which the Website doesn’t work.

1. Purposes, legal grounds, and how long we process and keep personal data

Generally, “personal information”, “personal data”, or similar terms refer to any information that identifies or relates to you. However, the exact meaning of PD may be determined by the laws of the country of your residence.

We adhere to the data minimization principle and only collect data essential for delivering our services through the Service.

The retention period is tailored to the:

specific data type;
user category (Partner/Customer/another);
legal or regulatory requirements;
safety, security, and fraud prevention;
unresolved account issues like credit or disputes.

We retain PD only as long as necessary for the purposes outlined in this Policy If you refuse to provide us with your PD, we won’t be able to provide all our services to you.

PURPOSE	LEGAL BASIS	DATA	WHOSE DATA
To render services to our Partners and Customers under the T&C and Partner Agreements (manage orders, purchases, accounts, render services).	Contract	Phone number Name and surname Email Photo Number of driver’s license(s) Driver’s car(s) information Geolocation Date of birth Payment details	Who uses our Service
To analyze, research, and understand your interaction with the Service	Consent	IP address Browser information Device ID Usage Data	Who interacts with the Service
To analyze, research, and understand your interaction with the Website	Legitimate interest in enhancing the quality of our services	Browser information IP addresses Device IDs Tools and Protocols Cookies	Who interacts with the Website
Respond to comments, questions, and requests	Legitimate interest in developing our business and satisfying our client's needs and requirements	Email Post address Name, surname Phone Position	Who requests, comments, or questions
Participation in promotions, competitions sponsored, promoted, or offered by us	Contract	Email Name and surname Phone number Position Date of birth	Who participates
Creating and keeping the Onde ID	Contract	Phone number Name and surname Email	Who uses or has used the Service
Offer you services that may be useful to you based on services previously ordered	Legitimate interest in developing our business and satisfying your needs.	Name and surname Email Phone	Who has used our Service
Marketing communication (emailing, advertising products, blog)	Consent	Email	Who has subscribed
To facilitate payment procedures in the Service	Contract	Phone number Payment details	Who makes payments in the Service
Enhancement of safety (including identification of fraud prevention, security, compliance, legal processes, and court orders) and issues relating to the user’s account (such as an outstanding credit or an unresolved claim or dispute).	Legitimate interest	Phone number Name and surname Email Photo Number of the driver’s license The car’s information Driver’s documents Date of birth Payment details	Who uses or has used the Service

Consent-Based Data Use and Legitimate Interests-Based Data Use:

You can withdraw your consent for data processing at any time where the legal basis is your consent.
If the legal basis for using your data is legitimate interests, you have the right to object to this use of your data.

Deletion of:
PD will be deleted within 90 days of your request.

Exceptions for retention:

A portion of PD may be retained to prevent fraud, scams, and other misconduct.
Onde may retain some data after a deletion request to comply with legal or regulatory obligations.
Retention may also occur for reasons explicitly stated in this Policy.

2. Where from and how do we obtain personal data?

You

When you use our Service or the Website, for example, sign up, fill in the order information, visit the Website, contact support, account and payment information, how you browse through, as well from our communications, complaints, or other interactions.

Your devices

Your computers, phones, and other web-connected devices to access our Service and the Website, transfer us your IP address, device, operating system, browser type, location data, and others.

Third parties

We engage with third-party processors. Their roles and responsibilities in data processing are clearly defined in our contracts with them.

Service providers: like reviewing accounts for fraud, transaction information services which, for example, include information about your purchases in the Service: date of purchase, currency, amount, payment type, and the last four digits of the card number;
Subprocessors: third-party subprocessors for cloud hosting, content delivery, data analysis, internal logging, fulfillment services, and email transmission, among others;
Analytics and cookie providers: We receive information by using cookies, social plugins, pixels, and tags for business purposes, such as providing information to help measure how users interact with our Website.

A detailed list of third parties Onde uses may be shown to you under your request within a reasonable time.

3. Who do we share your personal data with?

Advertising Partners	We may share with them a unique advertising identifier that is not attributable to you and is used to target advertising. We may also share your technical data with our advertising partners based on our legitimate interest.
Service providers under contract with us	They may use your PD to provide services to us, such as fraud/spam investigations, payment processing, analytics tools, and operations. These third parties are prohibited from using your PD for any other purpose. This section also includes services of third parties that are offered through our Service.
Business Transfers	Your PD may be transferred to the new owner in case of a business transfer, such as a merger or acquisition.
Our affiliates	Entities that are controlled by us or are under common control with us. Our affiliates may use PD we share in a manner consistent with this Privacy Policy.
Legal Requirements	After assessing necessity and proportionality, if required, for legal obligations or to protect legitimate interests, such as defending our rights in litigation or preventing fraud. We will not disclose data to protect against legal liability where no additional legitimate interests exist.

4. Cookies the website

With cookies (a cookie is a piece of data from a website that is stored within a web browser that the website can retrieve at a later time), Onde may collect information about:

Your device, including your IP address, operating system, and browser type;
Your usage of our Website including session data, preferences, approximate location, analytics data, login information, etc.

Cookies enable us to:

Estimate Onde’s audience size and usage patterns;
System administration and improvement;
Store information about preferences to customize the Website according to your interests;
Improve Onde’s services to deliver more personalized services;
Recognize you when you return to the Website;
Ensure the Service's content is presented effectively for you and your computer or smartphone.

These statistics are gathered in a way that doesn’t allow identifying individuals.

On the Website, you may refuse to accept optional but cannot refuse essential cookies (based on our legitimate interest). You can do the latter by only activating the setting on your browser, which allows you to refuse all the cookies. However, if you select this setting, you may be unable to access certain parts of the Website.

5. Where and how does Onde store your personal data

Onde keeps PD on servers of a third party in the European Union. The data that Onde collects may be transferred to and stored at a destination outside the European Economic Area (“EEA”). You agree to transfer, store, or process the data to destinations outside EEA by submitting PD. When transferring data outside the EEA, we employ safeguards such as Standard Contractual Clauses and ensure the receiving country has adequate data protection laws as determined by the European Commission.

When we transfer PD to trusted third parties in different countries, we sign Data Processing Agreements or Standard Contractual Clauses with them in some countries.

Onde restricts access to your data to individuals who need access to it to process it on Onde’s behalf. Agreements bind the employees and contractors who work with your data to be processors thereof. Onde will file a lawsuit or claim if they fail to meet the required data processing security.

We use neither automated decision-making nor PD to assess aspects of your personality (automated profiling) automatically.

6. Third-party integrations

Our service may involve integrations with or direct you to websites, apps, and services managed by third parties. By interacting with these third parties, you are providing information directly to the third party, not Onde, and you and your PD are subject to the third party’s privacy policy.

7. Marketing communication

We may send you marketing information without your consent only if you are our customer and the message we send you relates to our new products of the same type of product you have. It is our legitimate interest.

We send this information through direct emails or third-party email service providers.

You may stop receiving marketing and promotional information anytime by clicking "Unsubscribe" at the bottom of each email or sending us a direct request to unsubscribe you from further promotional emails.

8. Onde ID

Onde will securely store the login information and PD of the Partners, Customers, and any other Service users in its system called "Onde ID".

If a Customer wants to use the Service, Onde may share some of their Onde ID data with the Partner. The Partner may then use that data to provide the necessary services.

The Onde ID data may be shared outside the Service for facilitating logins and the performance of services by third parties if a Customer/Partner agrees to (for example, if there is a third party’s integration in the Service). In this case, such a Customer/Partner and the data they agreed to share will be subject to the third party’s privacy policies.

9. Your rights

You have a right to:

access your PD,
rectify the information we hold about you,
erase your PD,
restrict our use of your PD,
object to our use of your PD,
receive your PD in a usable electronic format (right to data portability),
revoke your consent,
complain with your local data protection authority,
file a complaint with a supervisory authority.

Other rights:
You have the right to

request that Onde not process your PD for marketing purposes.
ask Onde to amend any data it holds about you if it is inaccurate or misleading as to any matter of fact. Onde may also ask you to provide documents so that Onde can verify your identity.

To exercise any rights, contact Onde directly by post or email at hi@onde.app.

10. Changes to the Privacy Policy

Any changes Onde may make to the Policy in the future will be posted on this page. We will notify you via email or other ways before any changes. We will inform you in a reasonable time, not less than 3 days. The date of the most recent revisions will appear on this page.

11. Security

We use technical, physical, and administrative measures to protect your PD. You are responsible for your password and account info.

We are responsible for reporting a data breach without undue delay and, where feasible, not later than 72 hours after becoming aware of it.

Onde may post links to third-party websites on the Services. These links are not administered or verified by Onde. You access the links at your own risk. Onde makes no representations or warranties about the content of such websites and cannot be held liable for any losses you suffer from using such third-party websites. Onde recommends you read any third-party websites' privacy policies before providing information to them.

12. Contact and the previous version

Please submit any questions, comments, and requests regarding the Policy to hi@onde.app.

The Policy was updated on 01.09.2024 and is in force from the same date.