Privacy Policy

CABCY SYSTEMS LTD – Privacy Policy

Last updated: November 04, 2021

CABCY SYSTEMS LIMITED (“we”, “our” or “us”) is committed to protecting your privacy. This Privacy Policy explains how your personal information is collected, used, and disclosed by CABCY SYSTEMS LIMITED.

This Privacy Policy applies to our website alongside our applications (our “Service”), CABCY app. By accessing or using our Service, you signify that you have read, understood, and agree to our collection, storage, use, and disclosure of your personal information as described in this Privacy Policy and our Terms of Service.

INTERPRETATION AND DEFINITIONS

Definitions

For the purposes of this Privacy Policy:

  • Applications refers to iOS Driver CABCY app, iOS Customer CABCY app, Android Driver CABCY app, Android Customer CABCY app.
  • Account means a unique account created for you to access our Service or parts of our Service.
  • Company (referred to as either “the Company”, “We”, “Us” or “Our” in this Agreement) refers to CABCY SYSTEMS LIMITED.
  • Cookies are small files that are placed on your computer, mobile device or any other device by a website, containing the details of your browsing history on that website among its many uses.
  • Country refers to: Republic of Cyprus
  • Customer refers to a person that signs up to use the CABCY SYSTEMS LIMITED Service.Device means any device that can access the Service such as a computer, a cell phone or a digital tablet.
  • Data Controller
    CABCY SYSTEMS LIMITED is the data controller in respect of the personal data processed under this Privacy Policy. Our registered address is 33 Neas Engomis, 2409 Engomi, Nicosia, Cyprus. For privacy enquiries please contact: support@cab.com.cy
  • IP address: Every device connected to the Internet is assigned a number known as an Internet protocol (IP) address. These numbers are usually assigned in geographic blocks. An IP address can often be used to identify the location from which a device is connecting to the Internet.
  • Personal Data is any information that relates to an identified or identifiable individual. [Clarified and expanded below under “Types of Data Collected”.]
  • Service refers to the Website and Applications.
  • Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used.
  • Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
  • Website refers to CABCY SYSTEMS LIMITED, accessible from cab.com.cy
  • You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

COLLECTING YOUR PERSONAL DATA

Types of Data Collected

Personal Data

While using Our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you. Personally identifiable information may include, but is not limited to:

  • Email address
  • First name and last name
  • Phone number
  • Payment Information (card token, billing address) [we store payment tokens via our payment processor; we do not store full card PANs]
  • Address, State, Province, ZIP/Postal code, City
  • Trip Contact Data: pick-up/drop-off locations, booking date/time, notes you leave for drivers.
  • Location data (real-time GPS coordinates) while using the app to provide the service.
  • Device identifiers and app crash logs.
  • Usage Data

Usage Data 

Usage Data is collected automatically when using the Service.

Usage Data may include information such as your Device’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When you access the Service by or through a mobile device, we may collect certain information automatically, including, but not limited to, the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data.
We may also collect information that your browser sends whenever you visit our Service or when you access the Service by or through a mobile device.

Special categories of personal data. We do not intentionally collect special-category data (sensitive personal data) about you. If you choose to provide any such information in communications (for example, via support tickets), we will treat it appropriately and, where required by law, seek explicit consent.

Tracking Technologies and Cookies

We use Cookies and similar tracking technologies to track the activity on our Service and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze our Service. The technologies we use may include:

  • Cookies or Browser Cookies. A cookie is a small file placed on your Device. You can instruct your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if you do not accept Cookies, you may not be able to use some parts of our Service. Unless you have adjusted your browser setting so that it will refuse Cookies, our Service may use Cookies.
  • Web Beacons. Certain sections of our Service and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of a certain section and verifying system and server integrity).

USE OF YOUR PERSONAL DATA

  • The Company may use Personal Data for the following purposes:
  • To provide and maintain our Service, including to match passengers and drivers and to monitor journey completion. (Lawful basis: performance of contract).
  • To manage Your Account (Lawful basis: performance of contract / legal obligation).
  • For payment processing and refunds (Lawful basis: performance of contract and legal obligation).
  • To contact you: To contact you by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application’s push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation. (Lawful basis: contract performance / legitimate interest / consent for marketing).
  • To provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information. (Lawful basis: consent; you may opt out).
  • To manage your requests: To attend and manage your requests to us. (lawful basis: performance of a contract, legitimate interests, and where required, legal obligation).
  • For business transfers: We may use your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by us about our Service users is among the assets transferred. (lawful basis: legitimate interests, and where applicable, performance of a contract or legal obligation).
  • For other purposes: We may use your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Service, products, services, marketing and your experience.

Third Party Services

We may share the information that we collect, both personal and non-personal, with third parties such as advertisers, contest sponsors, promotional and marketing partners, and others who provide our content or whose products or services we think may interest you. We may also share it with our current and future affiliated companies and business partners, and if we are involved in a merger, asset sale or other business reorganization, we may also share or transfer your personal and non-personal information to our successors-in-interest.

We may engage trusted third party service providers to perform functions and provide services to us, such as hosting and maintaining our servers and the app, database storage and management, e-mail management, storage marketing, credit card processing, customer service and fulfilling orders for products and services you may purchase through the app. We will likely share your personal information, and possibly some non-personal information, with these third parties to enable them to perform these services for us and for you.

We may share portions of our log file data, including IP addresses, for analytics purposes with third parties such as web analytics partners, application developers, and ad networks. If your IP address is shared, it may be used to estimate general location and other technographics such as connection speed, whether you have visited the app in a shared location, and type of the device used to visit the app. They may aggregate information about our advertising and what you see on the app and then provide auditing, research and reporting for us and our advertisers. We may also disclose personal and non-personal information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate in order to respond to claims, legal process (including subpoenas), to protect our rights and interests or those of a third party, the safety of the public or any person, to prevent or stop any illegal, unethical, or legally actionable activity, or to otherwise comply with applicable court orders, laws, rules and regulations.

RETENTION OF YOUR PERSONAL DATA

The Company will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

  • Transaction and payment records: for tax and accounting purposes.
  • Trip records (including trip contact data, GPS logs): for dispute resolution, fraud prevention and regulatory compliance, unless local law requires otherwise.
  • Support tickets and correspondence.
  • Analytics and aggregated data.
  • Account data for inactive accounts.

We will delete or anonymise personal data when it is no longer required, unless we must retain it to comply with a legal obligation.

DELETION OF YOUR PERSONAL DATA 

You may request deletion of your account and personal data. Where deletion is requested we will delete or anonymise personal data that we no longer need, subject to legal and contractual retention obligations. Certain data (e.g., transaction records) may be retained in anonymised or limited form where required by law.

TRANSFER OF YOUR PERSONAL DATA

Your information, including Personal Data, is processed at the Company’s operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those from your jurisdiction.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

The Company will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.

DISCLOSURE OF YOUR PERSONAL DATA

Transportation Providers

If we disclose Trip Contact Data to Transportation Providers, we will limit the data to what is necessary to perform the service.

Business Transactions

If the Company is involved in a merger, acquisition or asset sale, your Personal Data may be transferred. We will provide notice before your Personal Data is transferred and becomes subject to a different Privacy Policy.

Law enforcement

Under certain circumstances, the Company may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Other legal requirements

The Company may disclose your Personal Data in the good faith belief that such action is necessary to:

  • Comply with a legal obligation
  • Protect and defend the rights or property of the Company
  • Prevent or investigate possible wrongdoing in connection with the Service
  • Protect the personal safety of Users of the Service or the public
  • Protect against legal liability

SECURITY OF YOUR PERSONAL DATA

The security of your Personal Data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. In the event of a personal data breach we will comply with applicable breach notification rules and notify the supervisory authority and affected data subjects when required by law.

YOUR RIGHTS 

Under applicable data protection laws (including the GDPR), you have certain rights in relation to your personal data. These include:

  • Right of access — you can request a copy of personal data we hold about you.
  • Right to rectification: you can request correction of inaccurate or incomplete data.
  • Right to erasure (“right to be forgotten”): subject to legal retention requirements.
  • Right to restriction of processing: in certain circumstances.
  • Right to data portability: for data you provided, in a commonly used format.
  • Right to object: to processing based on legitimate interests (we will assess and respond).
  • Right to withdraw consent: where processing is based on consent (withdrawal will not affect processing done prior to withdrawal).
  • Right to lodge a complaint with a supervisory authority (in Cyprus: Office of the Commissioner for Personal Data Protection).

To exercise any of the above rights, please contact our DPO at support@cab.com.cy.

Links to Other Websites

Our Service may contain links to other websites that are not operated by us. If you click on a third party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit. We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

CHANGES TO THIS PRIVACY POLICY

We may update Our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page and update the “Last updated” date at the top of this Privacy Policy. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

CONTACT US
If you have any questions about this Privacy Policy, you can contact us:

  • By completing the Contact Us form on this page on our website: https://cab.com.cy, or
  • By sending us an email to support@cab.com.cy