What information we collect

We collect three categories of information about you: information you provide, information we collect automatically, and information we obtain from other sources. We do not collect or process information about your racial or ethnic origin, political opinions or membership of any political association, religious or philosophical beliefs, trade-union membership, genetic data, biometric data, or data concerning a person’s sex life.

Information you provide

Registration and profile information, such as your name, phone number, email, country, city, preferred language, profile picture. Where permitted or required by law, we may collect emergency contact numbers.

Partner’s information, which may include partner’s license data and status, information about the vehicle (type, make, model, year of manufacture, color, registration certificate data, license plate, vehicle inspection report, vehicle photo), ID document data (including partner license, passport, state identification numbers), proof of identity, proof of residency, physical address, date of birth, taxation identifier number, relevant insurance, right to work, driving record, payment or banking information, and other documents which may be required by applicable regulations. Where permitted or required by law, we may conduct identity verification and/or background check. This may require collecting and processing such information as your photograph, ID document data, social security number and criminal record. This information may be processed by vendors on our behalf.

User generated content that you choose to upload through the Services, such as comments, ratings, and reviews for other Users.

Information in correspondence you send to us, which may include chat messages, emails, and recordings of phone calls you make to us.

Information we collect automatically

Location information. We collect Users’ location data to enable rides, for user support, for safety and fraud detection purposes, and to satisfy legal requirements. We collect location information (including GPS coordinates and WiFi data) based on your App settings, device permissions, and whether you are using the App as a Passenger or a Partner (where applicable):

- Passenger: We collect your device’s precise location when the App is running in the foreground (App open and on-screen) and when the App is running in the background (App open but not on-screen) from the time you request a ride until it ends. Passengers may use the App without enabling it to collect precise location data from their mobile devices by directly inputting your pick-up and drop-off address or coordinates into the App. This may affect the availability of App features.

- Partner: We collect your device’s precise location when the App is running in the foreground (App open and on-screen) and when the App is running in the background (App open but not on-screen) in the Partner mode. We may also collect precise location for a limited time after you exit Partner mode in order to detect and investigate ride incidents.

Transaction information. We collect transaction information related to the use of our Services, including the type of Services requested or provided, order details, payment transaction information, date and time the service was provided, amount charged, route and distance traveled, and payment method.

Usage information. We collect data about your use of our Services. This may include such data as access dates and times, App features or pages viewed, App or Website crashes and other system activity. We may also collect and use for marketing purposes the data related to third-party sites you have visited or services you used before interacting with our Services.

Communications information. We enable Users to communicate with each other and with us through the App. To facilitate this service, we receive data about the time and date of the communications and the content. We may also use this data for user support, safety and security purposes, to resolve disputes between users, to improve our Services, and for analytics (such as to measure and improve the effectiveness of our website).

Device information. We collect information about the device you use to access the Services, such as your device name, brand and model, user agent, IP address, mobile carrier, network type, time zone settings, language settings, advertising identifiers, browser type, operating system and its version, screen parameters, battery state, and installed applications that can be used for authentication purposes. We may also collect mobile sensor data, such as speed, direction, altitude, acceleration, deceleration, and other technical data. Cookies, Analytics, and Third-Party Technologies. We collect information through the use of cookies, pixels, tags and other similar tracking technologies (“Cookies”). Cookies are small text files that web servers place on your device. They automatically collect information, measure and analyze how you use websites and applications, and identify which web pages and ads you click on. The information we obtain through cookies helps us improve your PoolKaro experience (for example, by saving your preferences) and our marketing programs. Our service providers and business partners may use this information to display ads across your devices tailored to your preferences and characteristics. You can delete cookies and manage cookie settings in your web browser settings. Nevertheless, some cookies cannot be disabled since the functionality of some of our features depends on them. To learn more about these technologies, please see our Cookie Policy.

Information we obtain from other sources Third-party services. We may receive the information about Users from our service providers, which include background check and identity verification providers, insurance partners, financial services vendors and marketing providers. If you choose to use a third-party communication application (such as WhatsApp) or, sign up using a third-party social network or login service (such as Facebook), where this functionality is available, we may collect information from these services. Please, refer to the third-parties' privacy policies to find out how they treat your information. State authorities. We may receive information about Users from law enforcement agencies and other government authorities as part of a law enforcement request, during legal proceedings, or as required or authorized by law. Other Users or third parties. Sometimes Users or others may provide us with information about you, including through user support, or in connection with claims or disputes. We will only keep and use this information if we could have lawfully collected it from you. We will also take such steps (if any) as reasonable in the circumstances to let you know we have collected this information.
How we use your information We use the personal information we collect:
1. To enable you to use our Services
A. create and maintain your account, settings, and preferences;
B. verify your identity;
C. enable transportation services, or other services, as may be the case; D. calculate prices and facilitate payments;
E. enable communications between Users;
F. provide user support;
G. send non-marketing communications about the Service;
H. maintain accessibility, safety and stability of our App and websites, diagnose, prevent and resolve technical and service problems;
I. Comply with regulatory requirements related to our Services and your use of our Services.

2. To maintain and enhance safety and security of our Services and Poolkaro Users
A. prevent, detect and combat fraud, unsafe or unlawful behavior, and violations of our policies and rules;
B. authenticate Users;
C. verify that Partners and their vehicles meet safety requirements;
D. protect personal information, rights and legitimate interests of PoolKaro and our Users;
E. Investigate and resolve incidents, accidents, and insurance claims.

3. To improve existing and develop new features and products
A. perform testing, research, analysis, development and machine learning to improve your PoolKaro experience;
B. collect feedback regarding your PoolKaro experience;
C. develop new products, features and services.

4. To promote PoolKaro and our Services
A. send you marketing emails, text messages, push notifications, in-app communications and ads;
B. provide you personalized experiences, content and advertising on the App, our Website, and on third-party platforms;
C. organize contests, events and other promotions. For information about how to opt out of certain marketing communications (including ads), please see the section titled “Your rights and choices.”

5. To comply with legal requirements. We may use your personal information to comply with applicable laws, regulations, licenses, and industry standards and as part of legal proceedings and in response to law enforcement requests and as otherwise authorized or required by law.

6. Automated decision-making. We use personal information to make automated decisions relating to your use of our Services:
A. connecting Partners and Passenger (or other types of Users, as the case may be), based on such factors as availability and proximity;
B. determining User ratings, and deactivating users with low ratings;
C. flagging Users who are identified as having engaged in fraud, unsafe or harmful activities;
D. recommending an average price of a ride, based on such factors as distance, location and time. Where required by law, actions based on such processing occur only after human review and/or the possibility to appeal.

We know how important it is to keep your personal information confidential. In this section we describe when and with whom we may share your information that we collect. With other Users We share certain information about Users to enable the scheduling and provision of rides. This includes sharing:
A. Passenger information shared with Partner includes name and photo, rating, pickup and drop-off locations, number of trips, offered fare, comments and contact information.
B. Partner information shared with Passenger includes name and photo, information about the vehicle and its photo, location before and during the trip, ratings and reviews, number of trips, contact information. We may also be required to provide Passengers with receipts and invoices containing information such as the origin and destination of the trip, the total duration and distance of the trip, itemization of the total fare, partner’s name and taxation identifier number. We also include other information on those receipts if required by law. For the purposes of other services, we will share the information with other Users that is necessary for scheduling and provision of such services.

With service providers We may share your personal information with our service providers for business purposes, including:
A. payment processing and transaction fulfillment;
B. user and technical support;
C. background checks and identity verification;
D. insurance;
E. cloud storage;
F. content delivery, in-app messaging, in-app calling, push notifications;
G. anti-fraud;
H. advertising, marketing, and analytics;
I. consultants, lawyers, accountants, auditors, and other professional services;
J. Google, in connection with the use of Google Maps in the App (see Google’s privacy policy for information on their collection and use of data); K. social media companies, including Facebook, in connection with our use of their tools in the App and websites, if you opt to use these services (see Facebook’s privacy policies for information on their collection and use of data);
L. airports, railway stations.

Within corporate group We may share all of the information we collect with a parent, subsidiary, or other affiliate of our corporate group to help us provide the Services or conduct data processing in relation to the Services.
In connection with a business transfer We may transfer personal information we collect in connection with a substantial corporate transaction, such as a restructuring, merger, consolidation or asset sales, in which personal information is among the assets to be transferred. We will use our best endeavors to ensure that any recipient to whom we transfer your information will hold and use that information in accordance with this policy. For legal reasons We may disclose your personal information when it is necessary:
A. to comply with legal requirements, such as to respond to subpoenas, court orders, law enforcement requests, legal claims, or government inquiries;
B. to protect and defend the rights, interests, safety, and security of PoolKaro, our Users, or the public;
C. to comply with license or permit requirements and any applicable laws and regulations. With your consent We may share your personal information for other purposes pursuant to your consent or at your direction. When it is depersonalized We may share your personal information after it is aggregated or otherwise anonymized so that it is no longer personally identifying information.

Your rights and choices Accessing and updating your information. You may access, review and update certain profile information and other information you have chosen to provide to us either in your account settings or by contacting user support at support@poolkaro.com. Sharing location information. Your device may have controls that determine what information we collect or how we can use that information. For example, you can prevent your device from sharing location information through your device’s system settings. This will, however, impact our ability to provide you with the full range of Services. Opting out of push notifications. You can opt out of receiving push notifications through your device settings. Please note that opting out of receiving push notifications may impact your use of the App (such as receiving a notification that your ride has arrived). Unsubscribing from marketing emails and SMS messages. You can opt out of marketing emails and SMS messages by using the “unsubscribe” link or mechanism noted in such emails and SMS messages. Managing cookies. You can delete cookies and modify your cookie settings on your browser. You may need to separately manage cookies for each type of browser or device. If you choose to refuse, disable, or delete cookies, we may not be able to provide you with all of the requested Services. Do Not Track. Some browsers transmit “do-not-track” signals to websites. Because of differences in how browsers incorporate and activate this feature, we currently do not take action in response to these signals. Deleting your account and data. You can delete your account through the App settings or request the deletion of your account or your data by contacting user support at support@poolkaro.com. You may be asked to verify your account and identity. In some cases, we will be unable to delete your account or may retain certain information for legitimate business purposes, such as to complete the transaction for which we collected the personal information, collect on an outstanding balance, detect cybersecurity threats, debug or repair our Services, ensure another User’s right to exercise their free speech rights or other legal rights, enable solely internal uses that are reasonably aligned with the context for which the personal information was provided, prevent fraud, comply with legal or regulatory obligations, or to manage any claims in relation to the Services. When we retain such data, we do so in ways designed to prevent its use for other purposes. Asking us questions or raising a complaint. We will be happy to answer any questions you may have about this policy or about how we treat your information, or if you wish to make a complaint about how we have handled your personal information. Please, contact us at support@poolkaro.com. We will respond to your request consistent with applicable law and subject to proper verification of your account and identity.

How we store your information We retain your information for as long as necessary to provide you our Services and for the other purposes set out in this policy. The retention periods will be different depending on the type of information, the category of User to whom the information relates, and the purposes for which we use it. When we process your information to provide you with the Service, we keep this information for as long as you have an account with us. We may retain User information after account termination due to legal or regulatory requirements or for reasons stated in this policy, including as explained in the section titled “Deleting your account and data.” For example, we will retain your information if there is an outstanding debt associated with your account. We retain transactional information such as rides and payments for the period of time necessary to perform tax obligations. If you violate PoolKaro Terms of Use or rules, we may keep your information for as long as it may be necessary to investigate and resolve the violation. We also retain information for the purpose of responding to any legal claims in relation to the Services. How we protect your information We take reasonable and appropriate technical, administrative, and physical security measures, appropriate to the nature of the personal information at issue, designed to protect your personal information from loss, theft, misuse and unauthorized access, disclosure, alteration, and destruction. We regularly review our security measures to consider available new technology and methods. But guaranteed security does not exist either on or off the Internet. We cannot guarantee the security of your information, including against unauthorized intrusions or acts by third parties. However, we make commercially reasonable efforts to make the collection and security of such information consistent with this policy and all applicable laws and regulations.

General disclosures Protecting Children. Our Services are for adults and are not directed to children. Should an individual whom we know to be a child, under the age of 18, send personal information to us, we will use reasonable endeavors to ensure we do not further use or disclose that information and delete this data. If you believe a child has provided us with personal information, please contact us at support@poolkaro.com. Telephone Monitoring. As part of our user service assurance practice, telephone conversations over phones may be monitored or recorded as a part of normal business operations. Monitored or recorded calls will be used for quality assurance and training purposes. Cross border data transfers To support our global operations, we share your information with members of our corporate group and other entities outside of your country of residence as described in the “How we share your information” section. These entities are committed to using and storing information in compliance with applicable privacy laws and to implementing appropriate security measures to protect your information. We will take reasonable steps to ensure that any overseas recipient deals with your personal information in a manner consistent with how we deal with it.

Third-party collections Certain third parties may use automatic information collection technologies, including cross-site tracking technologies, to collect personal information about you or your device. These third parties may include, but are not limited to, your internet service provider, your web browser, your mobile service provider, your mobile device manufacturer, online advertisers, and data analytics companies. Additionally, our App and Website may contain links to third-party websites and to our social network accounts. Clicking on any such links means that the respective website or social network may receive information on from which website you accessed the platform and may collect other personal information. It is also possible, if you are currently logged in as a user to a social network, that the social network will link this information to any account you have with the social network. We encourage you to read the privacy policies of these other platforms before clicking on any links on our App or Website. We are not responsible for the privacy practices of third parties. We do not control any of these third parties or how they collect, use, or disclose your personal information. This policy is not applicable to third-party collection, use, or disclosure of your personal information. If you have any questions about the privacy practices of any third party, you should contact the responsible third party directly.
Changes We may update this policy from time to time to reflect the changes in laws or in how we provide our Services. When we update the Privacy Policy, we will notify you by updating the “Last Updated” date at the top of this page and by posting the new Privacy Policy and providing any other notice required by applicable law. We encourage you to periodically review this page to stay informed of our privacy practices. When you use PoolKaro, you are agreeing to the most recent terms of this policy.
Contact Questions, comments and requests regarding this policy should be addressed to: support@poolkaro.com.