Effective Date: 25 May 2018
Dash Apps Limited (trading as “Fleet”) (“we”, “us”, “Fleet”) are committed to protecting and respecting your privacy.
This policy (together with our Terms of Service) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By accessing our peer-to-peer car rental service platform (the “Services“) through Fleet’s applications for mobile, tablet and other smart devices (collectively, the “Application”), or visiting www.jointhefleet.com (the “Site”) you are accepting and consenting to the practices described in this policy.
For the purposes of this policy, Dash Apps Limited (a company registered in Ireland, with a registered office at Unit 8, Merrymeeting Shopping Centre, Rathnew, Co. Wicklow) is the Data Controller.
This policy covers the information practices relating to our company web sites and services offered now or in the future.
This policy may be amended or updated from time to time to reflect changes in our practices with respect to the processing of personal data, or changes in Irish or European Union law. We encourage you to read this policy carefully, and to regularly check this page to review any changes we might make in accordance with the terms of this policy.
Information We Collect About You
We may collect personal data about you from the following sources:
- Data you provide: This is information about you that you give us by filling in forms on our site and in our apps, or by corresponding with us by phone, e-mail or otherwise. It includes information you provide when you register to use our site, post a listing, avail of any car hire services or when you report a problem with our site. The information you give us may include your name, address, e-mail address and phone number, financial and credit card information, personal description, photograph, driving records and related personal data. We may obtain your personal data when you provide it to us e.g., where you contact us via email or telephone, or by any other means, or when you provide us with your business card.
- Relationship data: We may collect or obtain your personal data in the ordinary course of our relationship with you e.g., by registering with intent to rent or list vehicles
- Data you make public: We may collect or obtain your personal data that you manifestly choose to make public, including via social media e.g., we may collect information from your social media profile(s), if you make a public post about us.
- App data: We may collect or obtain your personal data when you download or use any of our Apps.
- Web site data: We may collect or obtain your personal data when you visit our web sites or use any features or resources available on or through a web site.
- Registration details: We may collect or obtain your personal data when you use, or register to use, any of our web sites, Apps, or services.
- Content and advertising information: If you choose to interact with any third-party content or advertising on a web site or in an App, we may receive personal data about you from the relevant third-party.
- Third party information: We may collect or obtain your personal data from third-parties who provide it to us e.g., credit reference agencies; law enforcement authorities; etc.
Creation of Personal Data
We may also create personal data about you, such as records of your interactions with us, and details of your purchase history for internal administration purposes and analysis.
Lawful Basis for Processing Personal Data
In processing your personal data in connection with the purposes set out in this policy, we may rely on one or more of the following legal bases, depending on the circumstances:
We may process your personal data where we have obtained your prior, express consent to the processing (this legal basis is only used in relation to processing that is entirely voluntary – it is not used for data processing that is necessary, legal or obligatory in any way)
We may process your personal data where the processing is necessary in connection with any contract that you may enter into with us;
Compliance with applicable law:
We may process your personal data where the processing is required by applicable law
We may process your personal data where the processing is necessary to protect the vital interests of any individual
We may process your personal data where we have a legitimate interest in carrying out the processing for the purpose of managing, operating or promoting our business, and that legitimate interest is not overridden by your interests, fundamental rights, or freedoms.
Sensitive Personal Data
We do not seek to collect or otherwise process your sensitive personal data in the ordinary course of our business. Where it becomes necessary to process your sensitive personal data for any reason, we rely on one of the following legal bases:
Compliance with applicable law:
- We may process your sensitive personal data where the processing is required or permitted by applicable law e.g. to comply with our diversity reporting obligations
Detection and prevention of crime:
- We may process your sensitive personal data where the processing is necessary for the detection or prevention of crime, including the prevention of fraud.
Establishment, exercise or defence of legal rights:
- We may process your sensitive personal data where the processing is necessary for the establishment, exercise or defence of legal rights.
- We may process your sensitive personal data where we have, in accordance with applicable law, obtained your prior, express consent prior to processing your sensitive personal data. This legal basis is only used in relation to processing that is entirely voluntary – it is not used for data processing that is necessary, legal or obligatory in any way.
Purposes for Which We May Process Your Personal Data
The purposes for which we may process personal data, subject to applicable law, include:
Provision of services to you:
- providing our web sites, Apps and services to you
- communicating with you in relation to those services and providing you with promotional items at your request or in connection with those services or similar services.
Our web sites and Apps:
- operating and managing our web sites and our Apps
- providing content to you
- displaying advertising and other information to you
- communicating and interacting with you via our web sites and our Apps
- identifying issues with our web sites and Apps and planning improvements to or creating new web sites and Apps
- notifying you of changes to any of our web sites, our Apps, or our services.
- communicating with you via any means (including via email, telephone, text message, social media, post or in person) for news items and other information in which you may be interested, subject to ensuring that such communications are provided to you in compliance with applicable law
- maintaining and updating your contact information where appropriate
- obtaining your prior ‘Opt-In’ consent where required.
- sales; finance
- corporate audit
- vendor management
- engaging with you for the purposes of obtaining your views on our services
- detecting, investigating and preventing breaches of policy
- criminal offences in accordance with applicable law
- establishing, exercising and defending legal rights
- compliance with our legal and regulatory obligations under applicable law
Improving our web sites, Apps, services:
- identifying issues with our web sites, our Apps, or our services
- planning improvements to our web sites, our Apps, or our services
- creating new web sites, Apps, or services
Disclosure of Personal Data to Third Parties
We may disclose your personal data to other entities within the company group, business partners, suppliers (including but not limited to AXA Insurance, Stripe and Verisk Analytics) and sub-contractors (for the performance of any contract we enter into with them or you for legitimate business purposes) for purposes which include operating our web sites and our Apps, and providing services to you, in accordance with applicable law.
In addition, we may disclose your personal data to:
- legal and regulatory authorities, upon request, or for the purposes of reporting any actual or suspected breach of applicable law or regulation
- outside professional advisors, accountants, auditors, or lawyers, subject to binding contractual obligations of confidentiality
- third party processors, e.g. payment services providers, data centres; etc., located anywhere in the world, subject to the requirements noted below.
- any relevant party, law enforcement agency or court, to the extent necessary for the establishment, exercise or defence of legal rights
- any relevant party for the purposes of prevention, investigation, detection or prosecution of criminal offences or the execution of criminal penalties, including safeguarding against and the prevention of threats to public security
- any relevant third-party acquirer(s), in the event that we sell or transfer all or any relevant portion of our business or assets, including in the event of a reorganisation, dissolution or liquidation.
If we engage a third-party processor to process your personal data, the processor will be subject to binding contractual obligations to:
- only process the personal data in accordance with our prior written instructions;
- use measures to protect the confidentiality and security of the Personal Data; together with any additional requirements under applicable law.
We may also disclose your personal information to third parties:
- In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets.
- If Dash Apps Limited or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
International Transfer of Personal Data
Because of the international nature of our business, we may need to transfer your personal data within the company or group, and to third-parties as noted in the ‘Disclosures’ section above, in connection with the purposes set out in this policy. For this reason, we may transfer your personal data to other countries that may have different laws and data protection compliance requirements to those that apply in the country in which you are located.
Where we transfer your personal data from the EEA to recipients located outside the EEA who are not in Adequate Jurisdictions, we do so based on standard contractual clauses. You may request a copy of our standard contractual clauses using the contact details provided.
We have implemented appropriate technical and organisational security measures designed to protect your personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, unauthorised access, and other unlawful or unauthorised forms of processing, in accordance with applicable Irish and European Union law.
As the internet is an open system, the transmission of information via the internet is not completely secure. Although we will implement all reasonable measures to protect your personal data, we cannot guarantee the security of your data transmitted to us using the internet – any such transmission is at your own risk and you are responsible for ensuring that any personal data that you send to us are sent securely.
We take every reasonable step to ensure that:
- your personal data that we process is accurate and kept up to date
- any of your personal data that we process which you inform us is inaccurate will be erased or rectified as per your instruction
We take every reasonable step to ensure that your personal data which we process is limited to the personal data reasonably necessary in connection with the purposes set out in this policy or as required to provide you services or access to our web sites and/or Apps.
Data Storage Retention
We will retain your personal information as needed to fulfil the purposes for which it was collected.
The criteria for determining the duration for which we will keep your personal data are as follows:
We will retain copies of your personal data in a form that permits identification only for as long as is necessary in connection with the purposes set out in this policy unless applicable law requires a longer retention period. We may retain your personal data for the duration of any period necessary to establish, exercise or defend any legal rights.
Dash Apps LTD will also retain usage data for internal analysis purposes. Usage data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.
If you no longer wish us to use your information in providing the Fleet platform to you, you may request that we erase your personal information and close your account (see "Right to withdraw consent" below). Please note that if you do this:
- We may retain some of your personal information as necessary for our legitimate business interests, such as fraud detection and prevention and enhancing safety. For example, if we suspend a Fleet account for fraud or safety reasons, we may retain certain information from that Fleet account to prevent that user from opening a new Fleet account in the future.
- We may retain and use your personal information to the extent necessary to comply with our legal obligations. For example, Fleet may keep some of your information for tax, legal reporting and auditing obligations.
- Information you have shared with others (e.g., reviews) may continue to be publicly visible on the Fleet platform, even after your Fleet account is cancelled. Additionally, some copies of your information (e.g., log records) may remain in our database, but are disassociated from personal identifiers.
- Because we maintain the Fleet platform to protect from accidental or malicious loss and destruction, residual copies of your personal information may not be removed from our backup systems for a limited period of time.
Where We Store Your Personal Data
The data that we collect from you will be stored inside the European Economic Area ("EEA").
All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted using SSL technology. data encryption, or scrambling technologies, and industry-standard firewalls. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. However, we take a number of steps to ensure best practices are followed.
Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
Your Legal Rights
Subject to applicable law, you may have several rights regarding the processing of your relevant personal data, including:
Right of access
You have the right to request access to, or copies of, your relevant personal data, together with information regarding the nature, processing and disclosure of those relevant personal data
Any access request may be subject to a fee (subject to statutory limits) to meet our costs in providing you with details of the information we hold about you.
Right of rectification
You have the right to correct inaccurate or incomplete personal data, including by means of providing a supplementary statement.
Right to be forgotten
In some cases - for example, when your personal data is no longer necessary in relation to the purposes for which they were collected - you have the right for your personal data to be erased.
Right to stop the processing of your data
You have the right to object to continued processing of your personal data by Dash Apps (please see “Right to withdraw consent” below). In such cases, your personal data will only be processed with your consent or for the exercise or defense of legal claims.
Right to data portability
Under certain circumstances provided by law, you have the right to receive a copy of your personal data in a structured, commonly used and machine-readable format and/or transmit those Personal Data to another data controller.
Right to withdraw consent
You may at any time object and withdraw your consent to our processing of your personal data by contacting us at firstname.lastname@example.org. Be aware that should you withdraw consent, you may no longer be able to use and access certain information or features of the Site, Application or Services.
To exercise one or more of these rights, or to ask a question about these rights or any other provision of this policy, or about our processing of your personal data, please use the contact details provided below.
Please note that: -
- we may require proof of your identity before we can give effect to these rights
- where your request requires the establishment of additional facts, e.g., a determination of whether any Processing is non-compliant with applicable law, we will investigate your request reasonably promptly, before deciding on what action to take.
Be advised that you have the right to apply directly to data protection authorities in your country for advice or in order to lodge a complaint if you have concerns about how we process your personal data.
When you join and access the Fleet service, we may contact you in a number of ways using the information you have provided during sign-up:
We may process your personal data to contact you via email (see below), telephone, direct mail or other communication formats to provide you with information regarding services that may be of interest to you.
If we provide services to you, we may send information to you regarding our services, upcoming promotions and other information that may be of interest to you, using the contact details that you have provided to us and always in compliance with applicable law.
You may unsubscribe from our promotional email list at any time by following the unsubscribe instructions included in every promotional email we send.
We will not send you promotional emails from a list you have selected to be unsubscribed from, but we may continue to contact you to the extent necessary for the purposes of any services you have requested or from additional lists you have signed up under.
Transactional and support
We use automatic transactional emails, SMS messages, and push notifications that are triggered by actions you take on the platform, such as requesting a car, creating a listing, changing a password, and other ways in which you conduct business with us.
Support emails, phone calls or SMS messages consist of direct 1-to-1 contact made by our staff to provide assistance in conducting transactions on the platform, and may include but are not limited to:
- Providing support for current, upcoming, or previous rentals;
- Helping you to complete our verification process;
- Ascertaining the current status of your account, listing, or intention to rent
- Requesting feedback about your use of the platform
You may opt out of certain types of messages using the settings feature on our website and phone apps. However, in general, you must be able to receive both transactional and support communications to continue using the Fleet platform.
To withdraw your consent to these forms of contact, users may deactivate their accounts by sending an email with the subject line “DEACTIVATE” to email@example.com and confirming, when we contact you, your intention to close your account.
Updates and promotions
When you sign up for the Fleet service, you consent to join our email list through which we will contact you to provide:
- Updates and newsletters about the Fleet service
- User education and onboarding emails that describe how to get the best use out of the Fleet
- Promotional and/or marketing emails we use to share new and popular cars, special offers, and discount codes
You may opt out of receiving these types of emails in two ways:
- Using the unsubscribe link at the bottom of each email and following instructions.
- Contacting Fleet support at firstname.lastname@example.org and requesting that we remove you from our update & promotions email list.
We use the following cookies:
Strictly necessary cookies. These are cookies that are required for the operation of our Site or Application. They include, for example, cookies that enable you to log into secure areas of our Site or Application.
Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our Site or Application when they are using it. This helps us to improve the way our Site or Application works, for example, by ensuring that users are finding what they are looking for easily.
Functionality cookies. These are used to recognise you when you return to our Site or Application. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
Targeting cookies. These cookies record your visit to our Site or Application. We will use this information to make our Site or Application and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
From 25/05/2018 these Terms take effect.