USER PRIVACY STATEMENT
Effective Date: October 1st 2017
Upass, Inc. (“We”, “Us”, “Our”) has developed a mobile application (“URBO”, “App”) that collects data from your device in order to provide you with relevant transport information for nearby services.
Urbo collects information about you when you use our mobile applications, websites, and other online products and services (collectively, the “Services”) and through other interactions and communications you have with us. Services are provided by Upass Inc., and this Privacy Statement applies to information collected and used by Upass Inc.
SCOPE AND APPLICATION
COLLECTION OF INFORMATION
INFORMATION YOU PROVIDE TO US
We collect information you provide directly to us, such as when you create or modify your account, request on-demand services, contact customer support, or otherwise communicate with us. This information may include: name, email, phone number, postal address, profile picture, payment method, items requested (for delivery services), delivery notes, and other information you choose to provide.
INFORMATION WE COLLECT THROUGH YOUR USE OF OUR SERVICES
When you use our Services, we collect information about you in the following general categories:
Location Information: Once you permit the URBO to access location services through the permission system used by your mobile operating system (“platform”), we collect the precise location of your device when the app is running in the foreground or background, including your latitude, longitude, time and speed of travel. We may also derive your approximate location from your IP address.
Contacts Information: If you permit the Urbo app to access the address book on your device through the permission system used by your mobile platform, we may access and store names and contact information from your address book to facilitate social interactions through our Services and for other purposes described in this Statement or at the time of consent or collection.
Transaction Information: We collect transaction details related to your use of our Services, including the type of service requested, date and time the service was provided, amount charged, distance traveled, and other related transaction details. Additionally, if someone uses your promo code, we may associate your name with that person. We also automatically collect usage details each time you use URBO, including the country of origin, the searches you make, the routes you interact with, the type of phone or OS you are using, etc.
Device Information: We may collect information about your mobile device, including, for example, the hardware model, operating system and version, software and file names and verions, preferred language, unique device identifier, advertising identifiers, serial number, device motion information, and mobile network information.
Log Information: When you interact with the Services, we collect server logs, which may include information like device IP address, access dates and times, app features or pages viewed, app crashes and other system activity, type of browser, and the third-party site or service you were using before interacting with our Services.
We collect your name, phone number, email address and other information you may provide when using the “Send Feedback” feature in the Settings view.
We collect contact information (email and/or push notification token) when you explicitly request to be notified when URBO supports a new market.
IMPORTANT INFORMATION ABOUT PLATFORM PERMISSIONS
Most mobile platforms (iOS, Android, etc.) have defined certain types of device data that apps cannot access without your consent. And these platforms have different permission systems for obtaining your consent. The iOS platform will alert you the first time the Urbo app wants permission to access certain types of data and will let you consent (or not consent) to that request. Android devices will notify you of the permissions that the Urbo app seeks before you first use the app, and your use of the app constitutes your consent. To learn about the platform-level permissions that the app seeks, please visit our new iOS Permissions page and Android Permissions page. Sometimes these permissions require more explanation than the platforms themselves provide, and the permissions we request will change over time, so we’ve created these pages to serve as authoritative and up-to-date resources for our users.
INFORMATION WE COLLECT FROM OTHER SOURCES
We may also receive information from other sources and combine that with information we collect through our Services. For example:
If you choose to link, create, or log in to your Urbo account with a payment provider (e.g., Google Wallet) or social media service (e.g., Facebook), or if you engage with a separate app or website that uses our API (or whose API we use), we may receive information about you or your connections from that site or app.
USE OF INFORMATION
We may use the information we collect about you to:
Provide, maintain, and improve our Services, including, for example, to facilitate payments, send receipts, provide products and services you request (and send related information), develop new features, provide customer support to Users, develop safety features, authenticate users, and send product updates and administrative messages;
Perform internal operations, including, for example, to prevent fraud and abuse of our Services; to troubleshoot software bugs and operational problems; to conduct data analysis, testing, and research; and to monitor and analyze usage and activity trends;
Send or facilitate communications between you and a contact of yours at your direction in connection with your use of certain features, such as referrals, invites, split fare requests, or ETA sharing;
Send you communications we think will be of interest to you, including information about products, services, promotions, news, and events of Urbo and other companies, where permissible and according to local applicable laws; and to process contest, sweepstake, or other promotion entries and fulfill any related awards;
Personalize and improve the Services, including to provide or recommend features, content, social connections, referrals, and advertisements.
We may transfer the information described in this Statement to, and process and store it in, the United States and other countries, some of which may have less protective data protection laws than the region in which you reside. Where this is the case, we will take appropriate measures to protect your personal information in accordance with this Statement. If you are in the EU or Switzerland, please see the Safe Harbor notice below.
Provide you with pertinent transport information for nearby services;
Understand your preferences so that we can customize URBO for you, such as recommending personalized transport options;
Measure usage of URBO, including usage of specific features and views;
Develop and improve URBO based on your feedback and interactions;
Guide product development and build new features;
Conduct research on users habits and how they use public transportation;
Identify and correct bugs and other problems with URBO;
Respond to your emails and help with support queries;
Subject to your consent, keep you posted from time to time on latest announcements and additional information;
Comply with law and regulations and lawful requests or orders.
The following are some examples of your options with regard to collection, use and disclosure of your information:
You can stop all collection of location data easily and at any time by disabling location services in your device’s settings or by uninstalling URBO.
You are not required to indicate any preferences (including setting your home and work address) in order to use URBO, since these are optional.
You can unsubscribe at any time from mailing lists announcing newly released cities by clicking the “Unsubscribe” link in the emails you may receive.
SHARING OF INFORMATION
We may share the information we collect about you as described in this Statement or as described at the time of collection or sharing, including as follows:
THROUGH OUR SERVICES
We may share your information:
In case you request assistance with the use of URBO, we might share such request, including your contact information, with a third party directly involved in the issue (i.e. if you inform us over email that certain transit schedules in the app are outdated, and we forward this message to the applicable transit agency).
With other riders if you use a ride-sharing service; and with other people, as directed by you, such as when you want to share your estimated time of arrival or split a fare with a friend;
With third parties to provide you a service you requested through a partnership or promotional offering made by a third party or us;
With the general public if you submit content in a public forum, such as blog comments, social media posts, or other features of our Services that are viewable by the general public;
With third parties with whom you choose to let us share information, for example other apps or websites that integrate with our API or Services, or those with an API or Service with which we integrate; and
In case of a prospective business transaction, you agree that URBO may disclose anonymous and aggregate information to another corporation in order for the parties to determine whether to proceed with such transaction. In case a business transaction is completed, you agree that any information may be transferred to the corporation that owns URBO or the relevant part of it in order to carry its business. A “business transaction” includes, but is not limited to, a reorganization, merger, purchase, sale or other acquisition or disposition of a corporation or any of its assets.
We also disclose anonymous and aggregate information to certain third parties for research, product development or other business purposes. For instance, we may share information with transit agencies to help them analyze and improve their services.
OTHER IMPORTANT SHARING
We may share your information:
With Urbo subsidiaries and affiliated entities that provide services or conduct data processing on our behalf, or for data centralization and / or logistics purposes;
With vendors, consultants, marketing partners, and other service providers who need access to such information to carry out work on our behalf;
In response to a request for information by a competent authority if we believe disclosure is in accordance with, or is otherwise required by, any applicable law, regulation, or legal process;
With law enforcement officials, government authorities, or other third parties if we believe your actions are inconsistent with our User agreements, Terms of Service, or policies, or to protect the rights, property, or safety of Urbo or others;
In connection with, or during negotiations of, any merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or into another company;
If we otherwise notify you and you consent to the sharing; and
In an aggregated and/or anonymized form which cannot reasonably be used to identify you.
SOCIAL SHARING FEATURES
The Services may integrate with social sharing features and other related tools which let you share actions you take on our Services with other apps, sites, or media, and vice versa. Your use of such features enables the sharing of information with your friends or the public, depending on the settings you establish with the social sharing service. Please refer to the privacy policies of those social sharing services for more information about how they handle the data you provide to or share through them.
Urbo App anonymously discloses your current location (latitude and longitude) with Uber in order to show you Uber offerings available nearby. Uber cannot access any of your personal information with this anonymous location data unless you request an Uber ride and subsequently launch the Uber app. If you wish to no longer share anonymous location data with Uber, you can disable Uber in URBO’s Settings view.
ANALYTICS AND ADVERTISING SERVICES PROVIDED BY OTHERS
U.S.-EU AND U.S.-SWISS SAFE HARBOR
Upass Inc. complies with the U.S.-EU and the U.S.-Swiss Safe Harbor frameworks as set forth by the U.S. Department of Commerce in connection with its processing of personal data about data subjects in European Union member countries and Switzerland. With respect to this data, Upass Inc. has certified that it adheres to the relevant Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about these Safe Harbor programs, and to view our certification, please visit the Safe Harbor website.
You may correct your account information at any time by logging into your online or in-app account. If you wish to cancel your account, please email us at email@example.com. Please note that in some cases we may retain certain information about you as required by law, or for legitimate business purposes to the extent permitted by law. For instance, if you have a standing credit or debt on your account, or if we believe you have committed fraud or violated our Terms, we may seek to resolve the issue before deleting your information.
Urbo will comply with individual’s requests regarding access, correction, and/or deletion of the personal data it stores in accordance with applicable law.
We request permission for our app’s collection of precise location from your device per the permission system used by your mobile operating system. If you initially permit the collection of this information, you can later disable it by changing the location settings on your mobile device. However, this will limit your ability to use certain features of our Services. Additionally, disabling our app’s collection of precise location from your device will not limit our ability to collect your trip location information from a Driver's device nor our ability to derive approximate location from your IP address.
We may also seek permission for our app’s collection and syncing of contact information from your device per the permission system used by your mobile operating system. If you initially permit the collection of this information, iOS users can later disable it by changing the contacts settings on your mobile device. The Android platform does not provide such a setting.
You may opt out of receiving promotional messages from us by following the instructions in those messages. If you opt out, we may still send you non-promotional communications, such as those about your account, about Services you have requested, or our ongoing business relations.
YOUR CALIFORNIA PRIVACY RIGHTS
California law permits residents of California to request certain details about how their information is shared with third parties for direct marketing purposes. Urbo does not share your personally identifiable information with third parties for the third parties’ direct marketing purposes unless you provide us with consent to do so.
COOKIES AND ADVERTISING
Please refer to our Cookie Statement for more information about your choices around cookies and related technologies.
We are committed to securing your information and we take reasonable physical, organizational and technical measures to protect your information against unauthorized access, use, disclosure, modification or destruction.
These safeguards include, but are not limited to:
- Storage on secure servers;
- Encryption of the communication channels;
- Limited access to employees and contractors on a “need-to-know” basis.
Although we take great efforts to protect your information, no security system can prevent all potential security breaches nor be immune from any wrongdoings or malfunctions.
We will retain your information as long as you use URBO and for a reasonable time thereafter.
RIGHT TO ACCESS AND REMOVAL
We store your information on servers located in EU (Germany).
If you would like to remove or access any information that we have collected through URBO that is stored on our servers, please contact us at firstname.lastname@example.org. On receiving such a request, we will use reasonable efforts to provide you or delete such information.
We do not knowingly collect, use or disclose information from children under the age of 13. If we learn that we have collected information of a child under 13 without first receiving parental consent, we will take steps to delete such information within a reasonable time. If you have reason to believe that a child under the age of 13 has provided information to us, please contact us and we will take steps to delete such information within a reasonable time.
CHANGES TO THE STATEMENT
If you have any questions about this Privacy Statement, please contact us at email@example.com.