eCabs (“we”, “us”, “our”) take the responsibility of your (“customer” “user” “you”) privacy seriously and work to the standards & legislation set by the General Data Protection Regulation (GDPR) 2018 and previously in accordance with the provisions of the Data Protection Act as contained in Chapter 440 of the Laws of Malta. This Privacy Policy describes how and why we obtain, store and process any data which can identify you. If you do not agree with this Privacy Policy in general or any part of it, you should not access the Websites, the App or use our services.
- What information does eCabs collect from you?
In order to be able to render its services to you, eCabs requires the collection, processing and storage of your personal data. It gathers such data pertaining to you, through numerous different channels, all of which are covered in sufficient detail below;
- Phone / Booking office
Customers may contact eCabs by phone for multiple reasons including inquiring or booking a cab, leaving feedback or registering a complaint. In order to process such communication eCabs may record such telephone call and you as a customer will be notified of this potential recording.
Customers may visit one of eCabs’ booking offices for multiple reasons including inquiring or booking a cab, leaving feedback or registering a complaint. In order to process such request or feedback eCabs may process the data provided by the customer which consists of names and surnames, pick up address, date and time, destination, geolocation and telephone/mobile numbers and any other information necessary for the carrying out of the service being offered.
eCabs use CCTV in our booking offices to record the general public purely for the purposes of security & safety of our operational staff and as a deterrent and prevention to crime and criminal activity.
eCabs may attach dash cameras to their vehicles, however such cameras shall never take footage of inside the vehicles but your image may be picked up by them when you enter or exit the vehicle.
The CCTV recordings are stored on a ‘Cloud’ system and accessible only by the Directors.
Anyone can ask to see images of recordings taken of them. Any request should be addressed to the Data Processing Officer on [email protected].
- Electronic-mail
Customers may contact eCabs by electronic mail for multiple reasons including inquiring or booking a cab, leaving feedback or registering a complaint, opening an account or to settle payment, or for any other matter, be it general or specific. In order to satisfy the customer’s request, eCabs may request names and surnames, pick up address, email address date and time, destination, geolocation and telephone/mobile numbers and any other information necessary for the carrying out of the service being offered.
As part of the process the customer is automatically opting in to e-mail communication as part of the service it is requesting or inquiring about. eCabs shall keep a record of all correspondence, including the email address provided by the customer.
eCabs may also request additional consent from the customer, such as the ticking of a box, in order for the customer to ‘Opt In’ to receive eCabs’ marketing and promotional material.
eCabs also offer the possibility of setting up an account which would require returned signed forms by email. The customer shall be asked to accept the eCabs terms and conditions and separately consent to this privacy policy. On signing the application form and accepting both the terms and conditions and privacy policy, the customers’ details are recorded securely on the eCabs server. Such customer details may include Credit Card details.
- Website
Customers may submit bookings or enquiries for eCabs’ services through the website www.ecabs.com.mt by inputting and sending personal data through the website’s contact form. Such data consists of names and surnames, pick up address, date and time, destination, geo-location and telephone/mobile numbers and any other information necessary for the carrying out of the service being offered. eCabs shall keep a record of all correspondence.
eCabs may also request additional consent from the customer, such as the ticking of a box, in order for the customer to ‘Opt In’ to receive eCabs’ marketing and promotional material.
eCabs website uses cookies to distinguish you from other users of their website. This helps eCabs to provide you with a more tailored experience when you browse the website and also allows eCabs to improve their site. By continuing to browse the site, you are agreeing to the use of cookies. The following cookies will be set;
- Google Analytics: Our Websites use Google Analytics to monitor and report on our website usage such as the number of visitors to the site, search phrases used to find us, pages visited on the site and time spent on the site. The statistics gathered are a necessary requirement in order for us to provide and improve our value-added products and services and to stay competitive. The cookies do not identify users nor associate your IP address with any personally identifiable information. These cookies are used to collect information about how visitors use our site. eCabs uses the information to compile reports and to help us improve the site. The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from and the pages they visited. Google’s privacy policy is found here: http://www.google.com/analytics/learn/privacy.html. Most web browsers allow some control over most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit: allaboutcookies.org.
To opt out of being tracked by Google Analytics across all websites visit: http://tools.google.com/dlpage/gaoptout.
eCabs website uses features from other websites that may leave cookies. These are third-party cookies and eCabs is unable to block or prevent them without removing an essential feature from our site. For information about those cookies you would need to check the originator’s website for their cookie policy.
When someone visits our website, eCabs may collect standard internet log information and details of visitor behaviour patterns. eCabs does this to find out things such as the number of visitors to the various parts of the site. eCabs collect this information in a way which does not identify anyone.
eCabs do not make any attempt to find out the identities of those visiting our website using the data in the logs. eCabs will not associate any log data gathered from our sites with any personally identifying information from any source.
Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
- eCabs Mobile Application (App)
Customers can book eCabs services by downloading and installing an Android (Google) or Apple based mobile App and registering their personal details.
By downloading, installing and registering with the App, the customer “Opts-In” to receiving “Automated” real-time text notifications, which notifications shall include the status of the booked cab using your mobile number and other notifications relating to eCabs services. The customer is also consenting to eCabs receiving personal information when the App is used, and this information is stored securely on the eCabs server. Such information includes contact details such as name, surname, email address and phone number, details concerning payment, geolocation of the passenger, the time and the destination of a journey.
On downloading the app, the user is prompted to accept the eCabs terms and conditions and separately consent to this privacy policy. Should the user wish to stop receiving real time notifications, he/she may switch off push notifications from the device or uninstall the application. In order to have user data removed, a user must contact eCabs as per ‘Your Rights’ section below.
Uninstalling the App does not mean that we will delete your data automatically. You must still request that we delete your data and such request shall be entertained limitedly to the data we are not obliges to retain.
- IP ADDRESSES AND DEVICE INFORMATION
eCabs may collect information about your computer, including where available your IP address, operating system and browser type, for system administration and to report aggregate information to our advertisers. This is statistical data about our users’ browsing actions and patterns, and does not identify any individual.
eCabs may collect information about your mobile telephone or handheld device (“Device”) or any computer you may use to download or stream a copy of our app onto your Device, including, where available the Device’s or Computer’s unique Devise identifiers, operating system, browser type and mobile network information as well as the Device’s telephone number, for system administration.
When you use one of eCabs’ location-enabled services, we may collect and process information about your actual location. Some of our services require your personal data for the feature to work. If you wish to use a particular feature, you will be asked to consent to your data being used for this purpose. Your consent can be withdrawn at any time by switching off the location-based services on your Device. If you require further details of how we use location-based services, you can request such information by contacting our Data Processing Officer on [email protected].
- Loyalty Scheme
When opting in to our loyalty scheme (“eCabs Circle) you authorise us to process and store your data necessary for the functioning of the loyalty scheme. This shall include but is not limited to name, surname, date of birth, gender, nationality and booking history.
- Other Data
Payment details you supply to us when booking through one of our channels.
- What happens when a booking is made?
On confirming a booking from the channels listed above, and after reading the terms and conditions and privacy policy, the customer is confirming that it has no objection to eCabs storing and processing their data, in a secure manner in line with Data Protection and GDPR Legislation as outlined in this privacy policy.
When a booking is confirmed, details are recorded securely on the eCabs booking system which is hosted by a third party. This data is held on the eCabs server, which is hosted by a third-party (“eCabs Server”) who is bound by the same data protection duties and GDPR law as is eCabs. Such data may be anonymized.
For the purposes of data collection as per preceding clause above, the term booking shall be interpreted in its widest sense and shall include any inquiry made through email or website, any complaint or feedback from any channel and any application for a loyalty card or opening an account.
- How does eCabs use this data?
eCabs use information held about you in the following ways:
- to communicate with you via telephone, email, SMS or via our App;
- to carry out our obligations arising from any bookings that you have made with us;
- to create records of bookings and to send you booking acknowledgments, confirmations, receipts and invoices;
- for reporting and data analysis purposes;
- to administer eCabs Circle;
- for insurance purposes;
- to share such information with third party fulfilment companies for the purposes of fulfilling a booking requested by you which is not being carried out by us;
- to ensure that content from our site and our app is presented in the most effective manner for you and for your computer;
- to provide you with information, products or services that you request from us or which we feel may interest you, where (if required to do so) you have consented to be contacted for such purposes;
- to allow you to participate in interactive features of our service, when you choose to do so;
- to notify you about changes to our Service;
- to meet customer service requirements and for complaint handling and feedback;
- to personalise our website and App to ensure content is presented in the most effective manner for you and your device;
- to monitor and analyse trends, usage and activity in connection with our website, apps and services and to improve our services;
eCabs will only contact you by electronic means (e-mail or SMS) with information about goods and services similar to those which eCabs have previously supplied to you.
If you do not want us to use your data in this way, please let eCabs know by contacting our Data Processing Officer on [email protected].
eCabs may also use and analyse the aggregate (collective data that relates to a group or category of services or customers, from which individual customer identities or characteristics have been removed) information collected through the analytics provision so that eCabs can administer, support, improve and develop their business.
- Where does eCabs store your personal data?
The data that we collect from you may be stored on the eCabs servers situated inside the European Economic Area (EEA). Where necessary it may be transferred to third parties for processing in line with our agreements with such third parties. We require all third parties to whom we disclose personal data to enter into a contract with us which includes stringent confidentiality obligations.
Your data may also be processed by staff who work for us or for one of our suppliers. Such staff may be engaged in, among other things, the fulfilment of your order and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy and relevant regulations.Once we have received your information, we will use strict procedures and security features to prevent unauthorised access.
- For how long does eCabs store your data?
eCabs retain personal data in the eCabs server for the following periods:
In order to determine the retention period of your personal data, we consider several criteria so that your personal data is not kept for longer than necessary. Such criteria include but are not limited to;
- the reason we hold your personal data;
- statutory obligations including the Laws of Malta and Transport Malta Regulations (we also adhere to any financial reporting obligations);
- whether we deem you to be a regular client, which classification is based on the services you request from us, whether you have chosen to receive our marketing communications and whether you have our App installed;
- whether you are no longer actively participating or engaging with us and whether you have requested eCabs to delete or alter your data; and
- our legitimate business interests in relation to managing our own rights, for example the defence of any claims.
We will retain your information as follows:
- your customer profile and account information (including your technical usage data), for 7 years after you last use our services;
- if you contact us via email we will keep your data for 5 years;
- records of bookings, lost property and complaints for a minimum of 12 months or as per statutory requirements.
- Who has access to your data?
eCabs may disclose your personal information to any member of our group or related company and also to third parties:
- in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;
- if eCabs or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets; or
- if eCabs is under a duty to disclose or share your personal data in order to comply with any legal obligation, process or request or in order to enforce or apply our terms and conditions of supply and/or any other agreements; or to protect the rights, property, or safety of eCabs, our customers, or others (this includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction).
- Your rights
You have the right to ask us not to process your personal data for marketing purposes. eCabs will always inform you (before collecting your data) if we intend to use your data for such purposes.
You may at any time decide to withdraw your consent and stop receiving marketing communications from us by using the ‘unsubscribe’ button at the bottom of one of our marketing emails.
You have the right to update and correct the personal information we hold about you. You also have the right to request from us all personal information that we hold that relates to you, to request restriction of the processing of that data and to request that we delete that data or object to continued processing where it is excessive or no longer required for the purpose for which it was collected.
Where allowed by applicable law, there may be an administrative charge for supply of copies of data and we may also require you to provide us with appropriate identification before we comply with this request. You also have the right to data portability.
You can exercise any of your rights by contacting our Data Processing Officer on [email protected].
- Changes to this Privacy Policy
This Privacy Policy will be updated from time to time to reflect changes in our business. It is therefore in your own interest to check the Privacy Policy page any time you access our web site so as to be aware of any changes which may occur from time to time.
- Contact
Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to the Data Processing Officer on [email protected].
The supervisory authority is the Office of the Information and Data Protection Commissioner which can be contacted at Level 2, Airways House, High Street, Sliema SLM 1549, Malta or by telephone on (+356) 2328 7100 or by email at [email protected]
Effective – 15th October 2020