This Privacy Notice provides an overview of who intelliTicket is and how intelliTicket collects, shares and uses personal data about you when you use the intelliTicket ride-hailing and payment app for passengers (the “App”). It also explains how you can exercise your rights under data protection law.

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1. Who is the data controller and our contact details

The controller of the personal data we collect through the App is: AWARE Systems LLC (referred to in this Notice as “intelliTicket“). intelliTicket‘s principal office is located at 800 Fairway Drive, Suite 495, Deerfield Beach, FL 33441. You can contact us by letter to this address.

intelliTicket has a data privacy manager. You can reach our data privacy manager most easily via the contact page on our website available at: https://www.intelli-ticket.com/contact/. Alternatively, you can write to the address above.

2. Important terms

“Personal data” means all information which relates to an identified or identifiable living person. This means that “personal data” includes information that identifies you directly (such as your name, postal address, e-mail address and telephone number) as well as information that allows you to be identified when it is combined with other information (such as an IP address).

“Processing“ means any operation performed on personal data, whether or not those operations are automated – e.g. collecting, organising, saving and deleting personal data are all types of processing (as well as a number of other types of activity).

“Journey” is a tour requested by a passenger through the App.

A “controller” of personal data is the organisation or person that decides how and why personal data will be processed – either alone or jointly with others.

A “processor” of personal data acts on behalf of, and on the instructions of, the data controller in relation to the personal data processing.

3. How we use your personal data

The personal data that we collect, and how we use that data, will vary depending on how you interact with our App. In this section, we have set out the various purposes for which we use personal data collected through our App.

If you have questions about or need further information concerning the legal basis on which we collect and use your personal data, including how we balance our legitimate interests against your rights and freedoms where applicable, please contact us using the contact details provided under section 1 above.

3.1. To register you as a user of the App.

Where you register as a user of the App, we will ask you to provide basic personal information to set up your account and verify your account details via email.

Categories of personal data used for this purpose:

Identity data: Given name, family name

Contact details: E-mail address, phone number, billing address

Optional: Profile picture; home and work address

Our lawful basis for processing this personal data: It is necessary to perform a contract with you. If you do not provide this information, we will not be able to register you as an App user. Where you have chosen to provide the information listed above as ‘optional’, we process this on the basis of your consent – you can delete this information from the App at any time.

3.2. To procure and manage journeys you request through the App.

We will need to process information about you in order to arrange and manage the journeys that you order through the App (whether you travel by bus, train, shuttle, or another mode of transport).

This includes allowing you to interact with maps using Mapbox (which is integrated into the App) so that you can pin the pick-up and drop off locations for your journey on the map or (where you have chosen to activate GPS settings) to identify your location via GPS. We use Mapbox in order to calculate the anticipated cost of your journey and to interactively show you the distance to the vehicle which will be carrying out your journey.

After you have procured a journey, your driver may phone you about your journey (for example, to inform you about delays or ask you to clarify the pick-up location) – however, we use a phone masking service that means the driver will not be able to see your phone number at any time.

Categories of personal data used for this purpose:

Identity data: Name; photo of face; address; e-mail address; date of birth; passenger/user ID; profile picture; blocked user accounts, salutation

Contact details: E-mail address; phone number

Journey data: Such as the time of the booking and the start/end location of your journey -Your start location may be collected by you placing a pin on a map or through your GPS coordinates, depending on the settings you have enabled. Enabling collection of GPS coordinates is optional. Where you have permitted access to GPS coordinates, we will only ever be able to see these where you are logged into and actively using the App on your device, live location (optional) – only when you have explicitly permitted it and only from the moment you order a ride until it starts. We will only ask for your permission once, but you can change it at any time in the App settings

Vehicle ID; trip information (like usage of minutes, distance, start and endpoint of tour); price paid and voucher amount; reservation and vehicle state; the areas in which journeys are available for booking; location of hire; date of last trip; energy level of vehicle; number of journeys and revenue in last 90 days

Technical data: Information about your device (device ID); IP address; country code; trip ID; app version; error codes; app download date

Financial data: Last four digits of credit card; payment transaction data; non-authorised transactions and payment rejection reasons

Optional: Home and work address – If you provide your addresses, we will use these to save your favourite journey routes on the App.

Our lawful basis for processing this personal data: It is necessary to perform a contract with you (or to take steps at your request prior to entering into a contract). If you do not provide this information, we will not be able to procure the journey or hire that you request or allow you to interact with maps via the App.

Where you have chosen to provide the information listed as ‘optional’, including your GPS coordinates, we process this on the basis of your consent – you can delete this information from the App at any time.

3.3. To purchase public transport tickets.

In order to allow you to purchase public transport tickets (in cities where this service is available) we need to process certain information about you.

Your personal data (e.g. name, date of birth, gender) might also be shared with the respective public transport company in order for the tickets to be properly issued and the data encoded into the QR code displayed as part of the ticket.

Categories of personal data used for this purpose:

Identity data: Name, salutation, date of birth, passenger ID, profile picture (optional)

Contact details: E-mail address; phone number, address

Location and related data: Language; country and city, country code, territory of business areas

Communication data: refund reason, correspondence with intelliTicket

Journey data: journey ID, ticket area selection, price level selection, start station and end station, copy of replacing ticket and/or fine, device ID, time of the booking

Technical data: Usage data e.g. log-in time and log-out times. IP address, application version, error codes

Financial data: Last four digits of credit card; payment transaction data; non-authorised transactions and payment rejection reasons

Our lawful basis for processing this personal data: It is necessary to perform a contract with you (or to take steps at your request prior to entering into a contract). If you do not provide this information, we will not be able to issue a ticket.

3.4. To respond to your enquiries and send you service-related communications.

You can contact intelliTicket in several ways, such as our online contact form (https:// https://www.intelli-ticket.com/contact/), by letter or by phone (where possible). Whenever you get in touch with intelliTicket, we process your personal data so that we can manage and respond to your enquiry or comment. We will also contact you from time to time with service communications (e.g., to provide a receipt for a journey you have taken or to notify you of updates to our Terms & Conditions).

Categories of personal data used for this purpose: Depending on how you choose to contact intelliTicket, we will process the following types of personal data:

Identity data: Name

Contact details: E-mail address; postal address; phone number

Location and related data: Language; country and city

Communications data: Content of your messages (including any attachments you provide)

Journey data: Relevant information about your journey or booking

Technical data: Usage data e.g., log-in time and log-out times

Our lawful basis for processing this personal data: Where you contact us to enter into or enforce a contract between you and intelliTicket, our lawful basis will be that the processing is necessary to perform a contract with you and/or to take steps at your request prior to entering into a contract.

In all other cases, we process this personal data as it is necessary for our legitimate interest in responding to passenger enquiries and in managing our relationship with customers and potential customers.

3.5. To take payment for your journey.

Where you pay for your journey directly via the App, we will process payment-related information about you.

Categories of personal data used for this purpose:

<p”>Identity data: Name

Contact details: E-mail address; phone number

Journey data: Start/end location of your journey; type of service; time and date of the booking/journey; distance; duration

Location and related data: Language; country

Financial data:

Currency

If you have provided a credit card as a means of payment: the first name and surname of the credit card owner, the issuer of the credit card; the first six and last four digits of the credit card number and the expiration date of the credit card

If you pay via PayPal: the e-mail address of your PayPal account

If you pay with Apple or Google Pay: the e-mail address of your account.

Technical data: Information about your device (such as device ID)

Employment data: If your journey is linked to a Business account or a mobility budget that is provided by your employer, we will process information about who your employer is

We process this personal information on the basis that it is necessary to perform a contract with you.

3.6. To verify your eligibility for rides covered by grants.

intelliTicket partnered with Rose Trolley LLC (401 N. Rosemary Ave., St. 9, West Palm Beach, FL 33401, USA) in order to make free rides available to eligible citizens in Palm Beach, Florida, USA. If you decide to take trips covered by the respective grant, we will need to verify your eligibility before you can request and manage these journeys through the App. This includes verifying that you meet the criteria set forth in the grant to ensure compliance. Verification may involve processing basic information such as your name, date of birth, and address. Once verified, you will be able to proceed with booking and managing the grant-covered journeys. Verification status will be maintained in accordance with the grant’s requirements, and periodic re-verification may be necessary as specified by the grant guidelines.

intelliTicket and Rose Trolley LLC will process your personal data together as so-called joint controllers.

Categories of personal data used for this purpose:

Identity data: Name, salutation, date of birth, passenger ID, profile picture (optional)

Contact details: E-mail address, phone number, address

Location and related data: Language; country and city, country code, territory of business areas

Communication data: refund reason, correspondence with intelliTicket

Journey data: journey ID, ticket area selection, start station and end station, device ID, time of the booking

Technical data: Usage data e.g. log-in time and log-out times. IP address, application version, error codes

Financial data: Last four digits of credit card; payment transaction data; non-authorised transactions and payment rejection reasons

Our lawful basis for processing this personal data: It is necessary to perform a contract with you (or to take steps at your request prior to entering into a contract). If you do not provide this information, we will not be able to issue a ticket.

3.7. To manage ratings of our drivers and passengers.

On the App, you can provide ratings of drivers and vehicles used to provide your journey: your rating will be aggregated with ratings from other passengers and used to display the driver’s average rating on the App. intelliTicket will be able to view your rating (from one to five stars) as well as the specific journey to which the rating is associated. However, your specific rating will not be shown to the driver you have rated and your associated journey details and individual rating will not be shown publicly via the App.

In addition, your driver can provide a rating for you as a passenger (for instance, to provide positive feedback or to inform us of problems). intelliTicket will use these ratings to create an average passenger rating score for you. Only you will be able to view this in your intelliTicket passenger profile. Your rating will not be displayed to drivers during the procurement of any journeys and your rating will not be used as the basis for any journey procurement or other decision about you. We urge our drivers to choose the passenger rating on the basis of the politeness and behaviour of the passenger.

Categories of personal data used for this purpose:

Rating data: Ratings you have given; ratings you have received

Journey data: Information about the journey to which the rating relates (such as start/end location and duration)

Our lawful basis for processing this personal data: We process this data on the basis of our legitimate interest in further developing and improving the quality of our services.

3.8. To fix bugs and improve the functionality of the App.

In order to fix issues, improve App functionality, and adjust the App to suit the needs of our passengers, we carry out technical analysis of how users interact with our App. Where possible, we will anonymise the personal data we use in order to carry out this activity.

Categories of personal data used for this purpose:

Identity data: Name; profile photo (where provided)

Contact details: E-mail address; phone number; workplace and home address (where provided)

Location and related data: Country; language; time zone; GPS coordinates at the time of booking (where provided)

Journey data: Start/end location

Technical information: Information about your device (Device ID; advertising ID)

Usage data: Information about your usage of our App

Our lawful basis for processing this personal data: It is necessary for our legitimate interests in improving the functionality and features of our App.

3.9. To send you news and personalised offers (marketing).

Where we are permitted to do so, we will send you news and personalised offers relating to products and services offered by intelliTicket and/or our third-party partners that we think may be of interest to you. Depending on the settings you have enabled in your App, we will send these to you by e-mail, text or through in-app or push notifications. You can withdraw your consent to receiving these marketing messages at any time (see section 7 (Your privacy rights) to find out how you can object to marketing messages).  You can also withdraw your consent to marketing communications via the “Data Protection Settings” of the intelliTicket passenger App (under your “Profile”), by turning off the toggle relating to “News and personalised offers”.

Categories of personal data used for this purpose:

Identity data: Name; passenger ID; profile picture (where provided); App profile type (business or privacy customer); registration status

Contact details: E-mail address; phone number; home address or business address (where provided)

Financial data: Method of payment; incentives

Journey data: Type of journey; journey status; GPS location data at the time of the booking and at the time of the end of the journey (where you have provided access) or pickup and destination locations

Technical information: Information about your device including the version of the App you are using; device ID, IP address; usage data (usage frequency, information relating to the download of the App); login information

Location and related data: Language; time zone; city

Our lawful basis for processing this personal data: Where we are permitted to do so by law, we process this information on the basis that it is necessary for our legitimate interest in marketing our services and providing relevant information to our customers and potential customers that we think will be of interest to them.In all other cases, we process this information on the basis of your consent.

3.10. To analyse the success of our marketing campaigns and advertise our services online.

We place non-targeted adverts for our services on third-party websites. We also evaluate and analyse the performance of our marketing campaigns and channels to understand how users become aware of our App, how they respond to specific ad campaigns and how they use the App. To do this, we collect and process certain information about the devices used by our users, their online behaviour and the content of websites they visit. The personal data we collect for this purpose are aggregated by our advertising partner and anonymised shortly after collection. Our service providers therefore cannot identify an individual from the personal data they receive.

Categories of personal data used for this purpose:

Technical data: IP address; user agent; advertising IDs; operating system of the device; device model; information about your journey; device information and settings; applications; downloads; website hits; information about how you use your device and your in-App behaviour; network carrier; as well as original device and attributed media sources

Location and related data: City; language

Preference data: Opt outs for advertising measures

Our lawful basis for processing this personal data: It is necessary for the purpose of our legitimate interests in advertising our services and understanding the effectiveness of, and improving, our marketing campaigns.

3.11. To conduct market research and surveys.

If you have agreed to receive market research and surveys from us (e.g., during registration of your account on the App or by activating the relevant toggle in the App’s privacy settings), we will send these to you from time to time. The surveys we send you will be personalised to you. Depending on the settings you have enabled, we will send these to you by e-mail, text or through in-app or push notifications. We do this so we can understand how you use our App and how we can improve our services.

Categories of personal data used for this purpose:

Identity data: Name; passenger ID; profile picture (if provided); app profile (business or private customer);

Contact details: E-mail address; residential and/or business address (if provided); phone number

Finance data: Payment method; invoice address on record (yes/no); tip value preference

Journey data: Registration date; type of journey (booking, try-out ride); registration/journey status; information about vouchers redeemed; information about favourite drivers and number of journeys taken/cancelled; journey rates and values; ratings.

Location and related data: Language; GPS coordinates at the start/end of journey (if provided) or start/end location of journey

Technical data: App version; usage data (usage frequency; information about the download of the App; date of the last login)

Our lawful basis for processing this data: We process this personal data on the basis of your consent.If you have provided your consent to this activity and you subsequently do not wish to receive these messages, you can easily withdraw your consent by de-activating the relevant toggle in your “Data Protection Settings” of the intelliTicket App (under your “Profile”). See also section 7 (Your privacy rights) on other ways you can withdraw consent and how we will implement your withdrawal.

3.12. To run our loyalty, referral and partnership programs.

If you take part in one of intelliTicket‘s loyalty or referral programs or partnership schemes, we will use your personal data as necessary to provide you with the relevant loyalty or partnership rewards and to confirm your participation in the program. The terms and conditions of the relevant program will be provided to you at the time you sign up to it. In particular, we run a referral scheme offering rewards when a new referred customer signs up and takes a certain number of journeys. If you are a passenger that is referred through this scheme, we will contact you to ask if you would like to sign up to our services, and we will collect and share information with the person who referred you about your sign-up activity.

Categories of personal data used for this purpose:

Identity data: Name

Journey data: App usage information such as the number of journeys taken; the cost of journeys; distance travelled

Our lawful basis for processing this data: Where participation in the program involves users signing up to a contract, we process this personal data on the basis that it is necessary for the performance of a contract with you (or to take steps at your request prior to entering into such a contract).

Otherwise, we process this personal data on the basis that it is necessary for our legitimate interest in conducting the loyalty or partnership program. However, your participation in any loyalty or partnership program is voluntary and you can choose not to participate and/or end your participation in accordance with the terms of the relevant program.

Lastly, the legal basis we rely on for the referral scheme is the consent of the referred passenger. You have a right to withdraw it at any time and please see section 7 (Your privacy rights) on how you can withdraw consent and how we will implement your withdrawal.

3.13. To handle accident reporting.

Unfortunately, accidents sometimes happen. If you or your driver is involved in an accident during a journey, we will use some of your personal information in order to carry out internal reporting, provide information to our insurers and other relevant third parties, and comply with our legal obligations.

Categories of personal data used for this purpose:

Identity data: Name

Contact details: E-mail address; phone number

Journey data: Details of the accident, including information your journey location, vehicle type, and journey time

Health data: if anyone has been injured during the accident

Our lawful basis for processing this data: It is necessary for the purpose of our legitimate interests in maintaining internal records about accidents that take place, notifying our mobility service providers of incidents in accordance with our contractual obligations, and processing insurance claims.

We will also process your personal information on the basis that it is necessary for compliance with a legal obligation to which we are subject, where this is the case as well as when it is necessary to for the establishment, exercise or defence of legal claims.

In limited instances, we will process this information to protect the vital interests of you or someone else.

3.14. To comply with our legal obligations.

We may use your personal data to provide information to competent authorities where we are required to do so by applicable laws or regulations (e.g., to our transport licensing authority or insurers).

The types of personal data we share for this purpose will vary depending on the nature of the legal obligation. However, common categories of personal data used for this purpose are:

Identity data: Name, details about your intelliTicket account.

Contact details: E-mail address; phone number.

Journey data: Information about your journeys, such as the start/end point.

Usage data: Information about your usage of our App.

3.15. Links to third-party websites.

Where you access a third party’s website – for example, by following a link to our LinkedIn page via our website – the provider of that website will be the controller of the personal data you provide on that site. For information about how they will handle your personal data, you should refer to the privacy notice on that website.

4. Third parties that we share your personal data with

We share your data with the following categories of recipients:

With our group companies who process personal information for purposes that are described in this Privacy Notice. We act as a joint controller with our group companies for these purposes. You may exercise your data subject rights under Privacy Laws in respect of and against each of the parties. However, to speed up the response, we would kindly ask you to exercise your rights at https://www.intelli-ticket.com/contact/. Our group companies, to which we may transfer personal data types described in this Privacy Notice, operate in the same sector as us and are based inside Germany/European Union.

Third party services providers and partners who provide data processing services to us or who otherwise process personal information for purposes that are described in this Privacy Notice. We work with the following categories of third party service providers:

Transportation companies and drivers to provide journeys that you request through the App. To be able to provide these services, these providers receive your:

Identity data: name; profile picture (if you have chosen to upload this to the App). Drivers will only be shown your profile picture temporarily around the time of your booking;

Journey data: Journey booking information including the start/end location; live location (with your consent);

Whilst your driver will be able to phone you about your journey (e.g., to warn you of traffic jams), we use a phone number masking service that means the driver will not be able to see your phone number;

Aggregated driver rating.

Third parties that help enhance the security and functionality of our App so that we can better tailor it to our customers’ needs: To be able to provide these services, these providers receive the personal data set out under section 3.8 above. We also use a provider of multi-factor authentication when you register on the App.

Payment service providers: To be able to provide these services, these providers receive the personal data set out under section 3.5 above.

Mapping software providers (such as Mapbox) so that we can allow you to interact with maps on the App: To be able to provide these services, these providers receive your: GPS location data (in an anonymised form so they cannot identify you)

Our advertising services and analysis partners: To be able to provide these services, these providers receive the personal data set out under section 3.9 and 3.10.

Customer communications services providers: To be able to provide these services, these providers receive the personal data set out under section 3.4.

Third parties involved in the grant program: To verify eligibility and manage journeys covered by the grant, we share personal data with entities responsible for the grant administration and oversight. This includes:

Eligibility data: Basic information such as your name, date of birth, and geographical origin to ensure compliance with the grant criteria.

Journey data: Details of the journeys booked under the grant program, including start/end locations and journey times.

Verification status: Information regarding your eligibility verification status, maintained in accordance with the grant’s requirements.

These entities will only have access to your data as necessary to fulfill their roles in the grant program and will handle your data in compliance with applicable privacy laws and regulations. To be able to provide these services, these providers receive the personal data set out under section 3.6.

Public transport companies, where you decide to purchase tickets for public transport: In order for the tickets to be properly issued and the data encoded into the QR code displayed as part of the ticket, these providers might receive your name, birthdate and salutation.

Any competent law enforcement body, regulatory, government agency, court or other third party where we believe disclosure is necessary:

• as a matter of applicable law or regulation,
• to exercise, establish or defend our legal rights (or where it is necessary for our legitimate interests in enabling our drivers or partners to exercise their legal rights), or
• to protect your vital interests or those of any other person.
• An actual or potential buyer (and its agents and advisers) in connection with any actual or proposed purchase, merger or acquisition of any part of our business, provided that we inform the buyer it must use your personal information only for the purposes disclosed in this Privacy Notice.
• Any other person with your consent to the disclosure.

You may exercise your rights under the Privacy Laws in respect of and against each of the parties (either intelliTicket or our third-party service mobility provider). However, to speed up the response, we would kindly ask you to exercise your rights via https://www.intelli-ticket.com/contact/.

5. Cookies and similar tracking technology

We use cookies and similar tracking technology (collectively, “Cookies”) to collect and use personal information about you, including to serve interest-based advertising. For further information about the types of Cookies we use, why, and how you can control Cookies, please see our Cookie Notice.

6. How we transfer your data internationally

In some cases, your personal information is transferred to, and processed in, countries other than the country in which you are resident. These countries may have data protection laws that are different to the laws of your country.

Our group companies are located inside the USA and Germany and we store all our data with a cloud service provider within the USA or in IT infrastructures and systems (employee computers) at our sites within the USA and/or Germany. Our third-party service providers and partners operate around the world. We have selected our service providers carefully to check that they will protect the personal data we share with them and we have engaged them in writing.

Where we transfer your personal data outside the USA or Germany, we have taken appropriate safeguards to require that your personal information will remain protected in accordance with this Privacy Notice.

7. Your Privacy Rights

You have the following data protection rights. You can exercise these rights by sending us a message to https://www.intelli-ticket.com/contact/or a letter to the address mentioned under section 1 above.

• You have the right to access, correct, update or request deletion of your personal data;
• you can ask us to restrict processing of your personal information or object to processing;
• you can request portability of your data;
• you have the right to opt-out of marketing communications we send you at any time (you can also exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you or through the Privacy menu on the “App”). We will implement your opt-out as soon as possible (due to technical reasons, this will be within 48 hours);
• if we have collected and process your personal data with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent;
• you may at any time lodge a complaint with the responsible data protection authority of the federal state of your residence if you are unhappy with how we have used your data.

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

8. How we keep your personal data secure

We have taken appropriate technical and organisational measures to keep your personal data secure (in particular to protect your personal data against unauthorised access by third parties, as well as accidental or intentional modification, loss or destruction). We review these measures periodically and change them in line with state of the art security processes.

The transfer of your personal data from your device (e.g., smartphone) to us is always encrypted. intelliTicket is PCI DSS (Payment Card Industry Data Security Standard) compliant.

9. How long we retain your data

We retain personal information we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or it to comply with applicable legal, tax or accounting requirements). In particular: inactive accounts are deleted after 3 years of inactivity.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

10. Updates and changes to this privacy notice

We may modify this Privacy Notice from time to time in the future in accordance with applicable data protection laws and regulations or in response to changing technical or legal developments. When we update our Privacy Notice, we will take appropriate measures to inform you, consistent with the significance of the changes we make.

Last updated: June 2024

Data Retention Policy