I. Scope

This Tracklimo Chauffeur App by Drivado and its Privacy Policy (TL) will inform you as an applicant to become a Drivado chauffeur, as partner of Drivado providing transportation services to Drivado's end customers or as a chauffeur for Drivado's end customers as to which personal data about you is processed by Drivado and for what purpose. For the use of Drivado's website and other Drivado services Drivado's general Privacy Policy and Cookie Policy apply: https://drivado.com/#/privacyPolicy

II. Name and Contact Information of the Controller

The controller for the processing of data within the meaning of the General Data Protection Regulation (GDPR) is:

Drivado Transfers Pvt. Ltd.,
Unit #506,
Merlin Infinite DN-51,
Street Number 11, DN Block,
Sector V, Bidhannagar, Kolkata,
West Bengal 700091, India

III. Application of partners or chauffeurs

Personal data provided will be processed as part of your application in order to determine your suitability for chauffeur services for Drivado's end customers. This includes information about whether a partner or chauffeur is appropriately qualified, licensed, experienced, sufficiently cleared by criminal background checks (if required or permitted by local law), capable of performing the chauffeur services and whether he fully complies with any and all guidelines or other requirements of Drivado.

Your data are necessary for the conclusion of a partner or transportation contract, otherwise we cannot process your application or offer you requests for transportation services. Drivado’s decision on your application is not solely based on automated processing.

Application data is usually not forwarded to external recipients, unless it is a Drivado contractor (see Art. 28 GDPR) or otherwise legally permitted. If your application is successful, your application data will be used for the contractual relationship with Drivado and the provision of professional chauffeur services for Drivado's end customers (see Section 6 below). Otherwise, your application data will generally be deleted after 6 months, unless there is an additional need or reason to store the data longer.

The legal basis for our processing of application data is Article 6 Paragraph 1 lit b GDPR (contract initiation). If you give us your consent to transmit personal data beyond the required extent, the legal basis is Art. 6 Paragraph 1 lit. a GDPR (consent).

IV. Chauffeur data, rides, contractual relationship

Drivado processes partner or chauffeur application data and partner or chauffeur data arising from the contractional relationship or the provision of Drivado chauffeur services (hereinafter “chauffeur data”). Chauffeur data will be used for Drivado services, i.e. for the fulfilment of the Framework Cooperation and Transportation Services Agreement with a partner, for transportation requests, transportation contracts or for accounting and payment purposes. This can include data like: Full name, gender, birth date, age, licenses, place of birth, physical address, email, telephone number, social security number, tax ID, pay-out preference or bank account, user ID, trainings and webinars, location data, ride status, tour milestones, vehicle number plate, vehicle details, customer orders, customer ratings, photographs, audio files, incident information, criminal background checks, compliance with Drivado guidelines company data.

Drivado provides chauffeur data to third parties, if necessary, in particular to end customers of Drivado so that the end customer can be transported in accordance with their booking and the transport can be processed, accounted and paid for. Chauffeur data can in such cases be transmitted in a third-party country outside of the European Union or the European Economic Area in which the end customer is located or planning to use Drivado services. Drivado cannot generally provide further information on the data protection level in the third-party country. An adequacy decision (see Art. 45 Paragraph 3 GDPR) or suitable guarantees (see Art. 46 GDPR) are not required for the transmission since the transmission is required for the performance of a contract between the data subject and the controller or to carry out pre-contractual measures upon request from the data subject (Art. 49 Paragraph 1 lit b GDPR) or because the transmission is required to enter into or to perform a contract concluded in the interest of the data subject by the controller with another natural or legal person (Art. 49 Paragraph 1 lit c GDPR).

The legal basis for the processing of chauffeur data is Art. 6 Paragraph 1 lit b GDPR (contract performance). If the chauffeur provides additional, voluntary information, the legal basis is chauffeurs’ consent according to Art. 6 Paragraph 1 lit a GDPR and our legitimate interest according to Art. 6 Paragraph 1 lit f GDPR.

In addition, Drivado processes chauffeur data in order to analyze, personalize and improve the use of Drivado services (e.g. ride reviews, to advertise Drivado services, to detect, limit and eliminate technical or process-related disruptions and problems, and to prevent illegal use of Drivado services (e.g. fraudulent booking, cyberattacks). For such purposes chauffeur data usually is not forwarded to recipients, unless it is to the chauffeurs’ employer or principal, a Drivado contractor (see Art. 28 GDPR) or if otherwise legally permitted (e.g. in order to assert or reject claims). The legal basis for the processing of chauffeur data is, in this respect, is Art. 6 Paragraph 1 lit f GDPR (Drivado's legitimate interest).

V. TracklimoChauffeur App and Drivado Partner Portal

Drivado operates an App for mobile devices (“Tracklimo”) and an online portal for Partners (“Tracklimo”, together “Drivado Chauffeur Tools”) for the communication with chauffeurs and the processing of end customer’s service requests. Data generated or used while utilising the Drivado Chauffeur Tools, i.e. all chauffeur tools data (e.g. login, password) or ride related data (e.g. date, time, pickup, drop-off, stopover, pax number, vehicle category/class, pick-up sign information and logo, end customer name, end customer mobile number, flight or train, reference number, booking comments, special needs, cancellations, changes to bookings, no shows and delays), are otherwise processed like chauffeur data for the purposes and as described in Section 6 above.

Drivado's decision on an offer by a partner or chauffeur can be solely based on automated processing. Such an automatic decision is required to conclude the contract (Art. 22 Paragraph 2 lit a GDPR). The data subject has the option of contacting us using the mentioned contact data (see section 2) in order to have an explanation or an intervention by a person or to express their point of view.

VI. GPS tracking, location data

With chauffeurs' consent, Drivado processes and uses GPS tracking or location data (i.e. longitude, latitude, speed, accuracy). Chauffeurs must first agree to this on their mobile device using the confirmation field or the system settings in Android or iOS ("Allow"). Chauffeurs’ position is then determined using the GPS data from the Drivado Chauffeur App (hereinafter “location data”) as soon as the chauffeur starts a journey (i.e. as soon as he presses the button "On the way to Pick up Location" in the Drivado Chauffeur App) and ends once the chauffeur presses the button "Finish Ride" in the Drivado Chauffeur App. In case the "Finish Ride" button is not pressed, tracking of location data stops automatically 120 minutes after the estimated time of arrival at the drop off point.

Purposes of processing are the execution of the contractual relationship (planning, disposition, arrangement, execution, accounting for and payment of transportation), to monitor the performance of the ride, to increase the quality of rides, to support Drivado, the chauffeur and the customer in case of questions or problems, the design and improvement of Drivado services, the detection, limitation and elimination of faults, errors or problems of a technical or process-related nature and the prevention or detection of illegal use (otherwise see Section 6 above).

Location data may be passed on to the current end customer of the chauffeur in order to facilitate and enhance the meeting with the chauffeur or for accounting and payment purposes. Otherwise, location data will not be transmitted to third parties, unless it is a Drivado contractor (see Art. 28 GDPR) or otherwise legally permitted.

Location data is processed safely and stored on encrypted media. Location data is not permanently linked to the chauffeurs' profile but stored separately. It can only be accessed according to a separate authorization concept, which allows only a limited group of people access for a limited time. Evaluations are otherwise carried out pseudo- or anonymised. Profiling (Art. 4 Paragraph 4 GDPR) using location data does not take place. Location data is not stored for more than 2 years and then deleted or anonymised.

The legal bases of the processing of location data by Drivado are Art. 6 Paragraph 1 lit a GDPR (consent) and Art. 6 Paragraph 1 lit b GDPR (contract performance and contract initiation). The described tracking of location data is necessary, so the chauffeur can use a navigation app at the same time whilst using the GPS tracking on the Drivado Chauffeur App. Rides can only be performed when GPS tracking is active and switched on for the Drivado Chauffeur App. The chauffeur can withdraw his consent to GPS tracking at any time by changing the device settings for the Drivado Chauffeur App. Such withdrawal of consent will not affect the processing of chauffeur’s location data tracked before driver’s withdrawal. The chauffeur can also withdraw his consent to further use of his location data at any time by sending us a message to that effect (communication channels see Sections 2 and 3 above). Such withdrawal of consent will not affect the processing of chauffeur's location data before driver's withdrawal.

VII. Credit Card Data

Tracklimo has no usage for credit card as no payment iss processed in the App or website.

VIII. Communication with Drivado

If you contact Drivado (e.g. by phone call, video conference, contact form, chat, messenger, text message, e-mail or via the Drivado Chauffeur App), the data provided by you will be processed to handle your matter and to answer your question. The legal bases are Art. 6 Paragraph 1 lit a GDPR (consent) and Art. 6 Paragraph 1 lit b GDPR (contract performance and contract initiation). Drivado will also use external services and tools to communicate with chauffeurs.

Drivado will process personal data from the communication, as far as possible in a pseudonymized or anonymized form, to analyse usage, design and improve Drivado services, to detect and remedy interruptions and technical or process-related problems and to prevent illegal usage of Drivado services (e.g. fraudulent booking, cyberattacks). The legal basis for the processing is Art. 6 Paragraph 1 lit f GDPR (Drivado's legitimate interest).

IX. Rights of data subjects

If your personal data is processed by Drivado, you are the data subject (Art. 4 No. 1 GDPR). As the data subject, you have the following rights in relation to the personal data affecting you:

X. Data Erasure and Storage Period

We will delete your personal data as soon as the legal basis for its processing no longer applies. In some cases, however, other legal bases can also apply, for example if processing is necessary for compliance with a legal obligation of Drivado (e.g. in accordance with commercial or tax law).

XI. Amendment or Update of this Chauffeur Privacy Policy

Drivado may update and amend this Driver Privacy Policy at any time. Chauffeurs will be informed and may be requested to provide consent again.

Drivado Transfers Pvt. Ltd.,
Unit #506,
Merlin Infinite DN-51,
Street Number 11, DN Block,
Sector V, Bidhannagar, Kolkata,
West Bengal 700091, India

Contact Us

Drivado Transfers Pvt. Ltd.,
Unit #506,
Merlin Infinite DN-51,
Street Number 11, DN Block,
Sector V, Bidhannagar, Kolkata,
West Bengal 700091, India
Support@drivado.com

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