1. The following terms and definitions are used in this policy:

1.1. “Personal Data” means any information relating directly or indirectly to a specific or definable individual (subject of personal data).

1.2. “Mobile Application” means the Authorized application program installed on the User’s device powered by the iOS, Android mobile operating systems, and allowing automating the User’s access to the database.

1.3. “Website” means a set of computers programs and other information contained in the information system, access to which is provided via the Internet by domain names, and/or network addresses that allow identifying sites on the Internet. TUDA

1.4. “TUDA” means a person that owns the right to use the website, as well as to use and distribute the mobile application, and that performs the processing of personal data of Users.

1.5. “User” means a person using the mobile application under a simple (not exclusive) license and providing his/her personal data to the TUDA.

1.6. “Client” means a person ordering a service through the Service.

1.7. “Processing of Personal Data” means any action (operation) or a set of actions (operations) performed with or without the use of the automation tools, with personal data, including collection, recording, systematization, accumulation, storage, correction (updating, modification), retrieval, use, transfer (distribution, provision, granting access), depersonalization, blocking, deletion, destruction of personal data.

1.8. “Automated Processing of Personal Data” means the processing of personal data by means of computer technology.

1.9. “Provision of Personal Data” means the actions aimed at disclosing personal data to a specific person or a specific group of persons.

1.10. “Blocking of Personal Data” means the temporary suspension of the processing of personal data (except in cases where the processing is necessary for correction of personal data).

1.11. “Destruction of Personal Data” means the actions resulting in the impossibility to restore the content of personal data in the personal data information system and/or resulting in the destruction of tangible media of personal data.

1.12. “Personal Data Information System” means a set of personal data contained in the databases and a set of information technologies and technical means ensuring the processing of personal data.

1.13. “Cookies” mean pieces of data sent by the website and stored on a computer, mobile phone, or another device from which the User accesses the website, and used to store data about the User’s actions on the website.

1.14. “Device Identifier” means unique data allowing identifying the User’s device on which the mobile application is installed, and provided by the device itself or calculated by the mobile application.

2. Installation of the mobile application on the device of the User or use of the mobile application in any other way, as well as use of the website shall mean the consent of the User to the terms of this policy, including the consent of the User to the processing of his/her personal data by the TUDA in cases where the provisions of the current legislation require such consent.

3. During the processing of personal data, the User shall be entitled:

3.1. to receive information regarding the processing of his/her personal data, also containing:

3.1.1. confirmation of the processing of personal data;

3.1.2. legal basis and purposes of the processing of personal data;

3.1.3. purposes and applied methods of the processing of personal data;

3.1.4. information about the name and location of the person processing personal data, information about the persons (except for the employees of the TUDA) that have access to personal data or to that personal data may be disclosed based on a contract with the TUDA or based on the current legislation;

3.1.5. processed personal data relating to the respective subject of personal data, the source of personal data unless otherwise provided for by the current legislation;

3.1.6. time of the processing of personal data, including time of its storage;

3.1.7. procedure for the exercise by the User of the rights provided for by the current legislation;

3.1.8. information on the completed or intended cross-border data transfer;

3.1.9. title or last name, first name, patronymic, and address of the person processing personal data on behalf of the TUDA, in case the processing is or is to be assigned to such a person;

3.1.10. other information provided for by the current legislation;

3.2. to require the TUDA to correct his/her personal data, to block or destroy it in cases where the personal data is incomplete, outdated, inaccurate, illegally obtained or is not necessary for the stated purpose of the processing, as well as to take legal measures to protect his/her rights;

3.3. to appeal the actions or omissions of the TUDA to an authorized body for the protection of the rights of subjects of personal data, or in court, in case the User believes that the TUDA processes his/her personal data in violation of the requirements of the current legislation or otherwise violates his/her rights and freedoms;

4. During the processing of personal data, TUDATuda shall:

4.1. provide the following information to the User at his/her request:

4.1.1. confirmation of the processing of personal data;

4.1.2. legal basis and purposes of the processing of personal data;

4.1.3. purposes and applied methods of the processing of personal data;

4.1.4. its title and location, information about the persons (except for employees) that have access to personal data or to that personal data may be disclosed based on a contract or based on the current legislation;

4.1.5. processed personal data of the User, the source of personal data unless otherwise provided for by the current legislation;

4.1.6. time of the processing of personal data, including time of its storage;

4.1.7. procedure for the exercise by the User of the rights provided for by the current legislation;

4.1.8. information on the completed or intended cross-border data transfer;

4.1.9. title or last name, first name, patronymic, and address of the person processing personal data on behalf of the TUDA, in case the processing is or is to be assigned to such a person;

4.1.10. other information provided for by the current legislation;

4.2. ensure the adoption of measures for the prevention of unauthorized access to the User’s personal data.

4.3. publish or otherwise provide unrestricted access to the document defining the policy regarding the processing of personal data, as well as to the information about the requirements implemented for the protection of personal data;

5. purpose of collecting and processing the User’s personal data is the conclusion of a contract for granting the User the right to use the mobile application. When collecting and processing personal data, the TUDA shall not pursue any purpose other than the purpose of the said contract.

6. The User’s personal data is stored on electronic media and processed with the use of automated personal data processing systems.

7. The TUDA collects and processes the following personal data of the User:

7.1. last name, first name, patronymic;

7.2. date of birth;

7.3. subscriber telephone number;

7.4. photograph;

7.5. series, number and date of issue of the document confirming the right to drive a vehicle;

7.6. license plate number of a vehicle.

7.7. The personal data of the User is destroyed by the TUDA within 24 hours from the moment of registration in the mobile application. After registration of the User, the personal data provided by the User is not stored or used in the future. 

8. The destruction of the Client’s personal data shall be carried out without the possibility of its subsequent restoration.

9. The TUDA uses and stores the following User’s data that is not personal data and does not allow identifying the User:

9.1. make, model and color of a vehicle;

9.2. numeric part of the license plate number of a vehicle;

9.3. name.

10. Only the employees of the TUDA may have access to the User’s personal data. The TUDA shall neither disclose the User’s personal data, nor provide access to it to third parties without the User’s prior consent, except in cases where personal data is provided at the request of authorized state bodies in accordance with the current legislation.

11. The TUDA shall implement the following measures to prevent unauthorized access to the User’s personal data. The TUDA shall:

11.1. appoint the employees responsible for the organization of the processing of personal data;

11.2. implement organizational and technical measures to ensure the security of the User’s personal data, namely:

11.2.1. identify threats to the security of personal data in the course of its processing in the personal data information systems;

11.2.2. organize a security regime for the premises in which the information system is housed, hindering the possibility of uncontrolled entry or occupancy of these premises by persons lacking the right to access such premises;

11.2.3. ensure the safety of personal data storage media;

11.2.4. approve the list of persons having access to personal data necessary for them to perform their official (job) duties;

11.2.5. use information security tools necessary to prevent unauthorized access to personal data;

11.2.6. assess the effectiveness of measures taken to ensure the security of personal data;

11.2.7. ensure the detection of unauthorized access to personal data and take measures;

11.2.8. restore personal data modified or destroyed due to unauthorized access (if such restoration is technically feasible);

11.2.9. establish the rules for access to personal data processed in the personal data information system;

11.2.10. control the measures implemented to ensure the security of personal data and the security level of the personal data information systems.

12. The User shall be entitled to require the TUDA to correct (update) his/her personal data, block or destroy it, in case the personal data is incomplete, outdated, inaccurate, illegally obtained or is not necessary for the stated purpose of processing, as well as to withdraw his/her consent to the processing of personal data by sending the appropriate request to the TUDA and/or demand in writing by registered mail with notification of delivery or its personal delivery at the address of the Service. The address of the TUDA is provided in the corresponding section of the website. The specified request/demand shall include the number of the main identifying document of the User or his/her representative, the date of issue of the specified document and the name of the issuing authority, the address of the User’s place of residence, information confirming the User’s relationship with the TUDA (ID-number of the User), or information that otherwise confirms the processing of personal data by the TUDA, request to correct, block or destroy the User’s personal data, or notice of withdrawal of consent to the processing of personal data, signature of the User or his/her representative. The TUDA shall give a reasoned response on the merits of the User’s request/demand within 30 calendar days from the date of its receipt.

Geolocation Data 

13. The TUDA receives data on the location of the User (geolocation data) through the mobile application. Geolocation data is transmitted to the TUDA only during the use of the mobile application. The User, at his/her discretion, can prohibit the transmission of geolocation data by changing the corresponding settings in his/her mobile device however, this may lead to the impossibility of using the mobile application.

14. For the purpose of providing the Client with transport services, the TUDA can provide the Client with data on the location of the User.

15. In order to be able to pay the license fee by cashless payment using bank cards, the User can link a bank card to his/her ID-number. The User shall link the bank card independently in the mobile application by providing the following data:

15.1. bank card number;

15.2. bank card expiration date;

15.3. bank card holder full name;

15.4. bank card security code.

16. Cashless payment using bank cards shall be carried out in accordance with the international payment systems rules on the principles of confidentiality and security of payment. The security of the data provided by the User shall be ensured by the compliance of the procedures with the requirements of the Payment Card Industry Data Security Standard, and no one, including the TUDA, can obtain the data. Bank card data shall be entered on the secure payment page of the acquiring bank providing the option of cashless payment for services.

17. In order to withdraw funds from the personal account, the User shall provide the TUDA with data on the account opened with a credit institution and other information necessary for transferring funds, including the User’s personal data, namely:

17.1. bank identification code of the credit institution;

17.2. recipient’s account number with a credit institution;

17.3. recipient’s last name, first name, patronymic;

17.4. debit or credit (bank) card number.

18. The data provided by the User for the purpose of withdrawing funds from the personal account does not allow the TUDA to perform any operations, except for the operations of crediting funds to the User’s bank account.

Cookies 

19. The TUDA can use the following types of cookies:

19.1. Strictly necessary cookies. They are necessary to navigate the website and use the requested services. Cookies of this type are used when the User registers and logs in. The services requested by the User become unavailable without them. These cookies are essential and can be either persistent or temporary. Without the use of this type of cookies, the website does not function properly.

19.2. Performance cookies. They collect website usage statistics. These files do not access the Client’s personal information. All information collected by these cookies is statistical and anonymous. The purposes of using these cookies are:

19.2.1. obtaining the website usage statistics;

19.2.2. evaluating the effectiveness of advertising campaigns.

These cookies can be persistent or temporary and can relate to both essential and third-party cookies.

19.3. Functionality cookies. They are used to store information provided by the User (such as username, language, or location). These files use anonymized information and do not track the User’s actions on other websites. The purposes of using these cookies are:

19.3.1. storing information about whether any service has been provided to the User before;

19.3.2. improving the quality of online experience in general by storing the preferences selected by the User.

These cookies can be persistent or temporary and can relate to both essential and third-party cookies.

19.4. Advertising cookies. They are used to manage advertising materials on the website, limit the number of times an ad is viewed by a user, as well as to evaluate the effectiveness of advertising campaigns. Advertising cookies are placed by third parties, for example, advertisers and their agents. These files are associated with advertising on the website provided by third-party companies. They can be either persistent or temporary.

20. The User can use the settings of the browser used by him/her in order to block or delete cookies, as well as to limit their functioning.

21. The TUDA, by means of the mobile application, receives data about the User’s device, applications installed on it and the Internet connection. This category includes information about the device model, operating system, browser data, IP address, device identifiers.

22. The collected data about the device of the User does not contain the User’s personal data.

23. The purpose of collecting information about the device of the User is the internal accounting of users of the mobile application, as well as improvement of its operation.

24. The TUDA, through the mobile application, receives data on the operator that provides the User with mobile phone (cellular) services.

25. The collected data on the mobile network operator does not contain personal data of the User.

26. The purpose of collecting data on the mobile network operator is to automatically determine in the mobile application settings the data on the User’s country of residence and the language of the application interface.

27. The TUDA retains the history of orders executed by the User, namely the time of the start of the order execution, the address of the pick-up point, the intermediate and drop-off points of the route, the rate applied, the payment method and other information specified by the Client.

28. The purpose of collecting order history information is the improvement of the quality of provided services by automatic filling in the order information using the previously obtained data, which reduces the order creation time.