Liftago, a.s., ID no.: 24278777, Karlovo náměstí 313/8, Nové Město, 120 00 Praha 2, file no.: 21666 incorporated with the Municipal Court in Prague (also as “LIFTAGO”), and ADLER Mobility, s.r.o., ID no.: 29138787, file no.: C 203226 incorporated with the Municipal Court in Prague (also as “ADLER”), as the joint controllers of personal data (henceforth also as “we”, “Companies” or “our company”) pay great attention to the protection of personal data. In this document you will find information about the type of data that we process, regarding in particular our customers (LIFTAGO platform users), whether the data are processed on the basis of consent or some other legal grounds, the purpose for which we use the data, to whom we may transfer the data and what are your rights in connection with the processing of your personal data.

These Principles are prepared in compliance with the legal regulations regarding the processing of personal data, including in particular Regulation of the European Parliament and of the Council (EU) 2016/679 of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) (hereinafter as “GDPR”).

  1. Definition of basic terms
    • Expressions “Controller”, “Joint Controllers”, “Processor”, “Personal Data”, “Processing” used in this text need to be interpreted in the context of GDPR:
      • Controller under Article 4(7) GDPR means any natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data. In relation to your personal data we act as the controller.

Where two or more controllers jointly determine the purposes and means of processing, they are “joint controllers” as defined in Article 26 GDPR. The data subject must be informed on the essential initial arrangements between the joint controllers to determine their respective responsibilities, in particular as regards the exercising of the rights of data subjects and their respective duties to provide information referred to in Articles 13 and 14 GDPR.

  • Processor as defined in Article 4(8) GDPR means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controllers.
  • Personal data means all information relating to an identified or identifiable natural person (i.e. the data subject).
  • Processing of personal data under Article 4(2) GDPR means any operation or set of operations with personal data or sets of personal data which is performed with or without automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
  • LIFTAGO is a technological platform which is operated by the Companies and which connects the providers of transport/taxi services (drivers) and mobile customers/passengers and is accessible via a mobile application, or a website.
  • Definition of responsibilities of Joint Controllers ADLER Mobility, s.r.o. is a subsidiary of Liftago, a.s.—the operator of the LIFTAGO technological platform, and as such ensures the operation and supply of the LIFTAGO services on the territory of the Czech republic and the business activities, including customer support. ADLER is under the General Terms and Conditions the contractual partner of LIFTAGO users (passengers and drivers) on the territory of the Czech Republic. Liftago is the parent company performing the central management of the group and is the operator of the website at www.liftago.com and www.liftago.cz. Hence ADLER is responsible towards data subjects for the processing of personal data, except for the processing at the website.
  1. What is the purpose for which we process your personal data?
    • We process your personal data only for the purposes of which you have been informed by our Company. What personal data we process and for what purpose depends on the manner in which you have provided your personal data to us. Via our website at www.liftago.com or www.liftago.cz or the “LIFTAGO” mobile application you have the opportunity to provide us with data such as:

 

  • Visitor to our website

If you visit our website at www.liftago.com or www.liftago.cz, we automatically process some of your personal data to the extent, for the purpose and for the period and for the reason (legal grounds) specified here:

Purpose Scope of processed data Legal grounds Period of processing
Improvement of website Data on your behaviour at the website or (through cookies). Our company’s legitimate interest in improving our website. 26 months from the last visit to our website
Preparation of statistics and reports on the use of the website Data on your behaviour at the website or (through cookies). Our company’s legitimate interest in the measurement of the efficiency of our website, including the advertisements on the website. 26 months from the last visit to our website

You have the right to object to the processing of your personal data for the purpose of pursuing our legitimate interest in improving and measuring the efficiency of our website. If there is no legitimate reason for us to continue the processing of the personal data for these purposes despite your objection, we will terminate the processing of your personal data in this context.

  • LIFTAGO user—passenger
    • Passenger registration in LIFTAGO application

By means of the registration form you, as the customer—passenger, have the opportunity to create your user profile in the LIFTAGO application through which you can use our services. In this case we process your personal data to the extent, for the purpose and for the reason (legal ground) specified here:

Purpose Scope of processed data Legal grounds Period of processing
Registration of user, management and administration of user profile. First name, surname, phone number, e-mail address, IP address, user ID assigned by us, unidirectional hash of payment card Necessary for performance of contract, or for implementation of measures adopted before the entry into contract during your application for registration. Until cancellation of registration by user, however, at the maximum for 3 years from the last login.

For you the statement of these personal data for the purposes of user registration, management and administration of the user profile is entirely voluntary, nevertheless without these data we are not able to set up, manage and administer your user profile (account).

  • Inserting photo (passenger portrait) in the user profile

Inserting your photo in your user profile is entirely optional. In this case we process your personal data to the extent, for the purpose and for the reason (legal ground) specified here:

Purpose Scope of processed data Legal grounds Period of processing
Recognition for provision of service. Portrait photo Consent for processing of personal data Until withdrawal of consent for personal data processing or until erasure of these data by user in his or her user profile.

For you the statement of these personal data is entirely voluntary. You always have the right to withdraw your consent for the processing of personal data in the manner specified below in par. 4.2.

  • Use of LIFTAGO application by passenger

We process your personal data that you have provided to us during the registration and use of the LIFTAGO application and some other data concerning you specified in the table below to the extent, for the purpose and for the reason (legal ground) specified here:

Purpose Scope of processed data Legal grounds Period of processing
Provision of LIFTAGO services. First name, surname, phone number, e-mail address, user ID assigned by us, unidirectional hash of payment card, localization data, GPS coordinates for the time from ordering the service to the end of the ride) information on mobile phone type Necessary for performance of contract Localization data (GPS coordinates for the time from ordering the service to the end of the ride) For 3 years from the last provision of the LIFTAGO service.
First name, surname, phone number, e-mail address, IP address, user ID assigned by us, unidirectional hash of payment card, information on mobile phone type For 3 years from the expiry of contract.
Basic data on legal relationship and its existence (first name, surname, contact data). For 10 years from the expiry of contract.

If you decide to use LIFTAGO services, these data are necessary for us to be able to provide these services, that is, satisfy your demand for a car and procure for you the passenger transportation service based your demand.

  • Sending product and service offers and tailor-made offers

We want to stay in contact with you. To that end we process your personal data to the extent, for the purpose and for the reason (legal ground) specified here:

Purpose Scope of processed data Legal grounds Period of processing
Sending our product and service offers and tailor-made offers.

 

First name, surname, e-mail address, phone number, user ID assigned by us, localization data (GPS coordinates for the time from ordering the service to the end of the ride) Legitimate interest in staying in contact with you and send you special offers tailored to your needs. For the duration of the legitimate interest, however, at the maximum for 3 years from the last use of the LIFTAGO services.

We will appreciate if we stay in contact so that we can send you our product and service offers as well as customized offers. To avoid sending you offers you are not interested in, we use the information on the LIFTAGO service that you use. However, we do not want to cause you any inconvenience, therefore you have the opportunity to refuse the delivery of commercial communications in the manner specified below and in each single commercial communication (see par. 4.9).

You have the right to object to the processing of your personal data for the purposes of sending commercial communications and based on the objection we will stop sending you commercial communications and terminate the processing of your personal data in this context.

  • Sending product and service offers and tailor-made offers of our business partners

We would appreciate if we could send you commercial communications containing newsletters and product and service offers of your business partners as well as tailor-made offers. In this case we process your personal data to the extent, for the purpose and for the reason (legal ground) specified here:

Purpose Scope of processed data Právní titul Doba zpracování
Sending product and service offers and tailor-made offers of our business partners. First name, surname, e-mail address, phone number, user ID assigned by us, localization data (GPS coordinates for the time from ordering the service to the end of the ride) Consent for processing of personal data and sending of commercial communications. Until withdrawal of consent for personal data processing and sending of commercial communications.

For you the statement of these personal data is entirely voluntary, however, these data are necessary so that we can send you commercial communications with the product and service offers of our business partners.

 

To avoid sending you offers you are not interested in, we use the information on the LIFTAGO service that you use.

 

You always have the right to withdraw your consent for the processing of personal data in the manner specified below in par. 4.2.

 

  • LIFTAGO user—driver
    • Driver registration in LIFTAGO application

By means of the registration form you have the opportunity to create your driver profile in the LIFTAGO application through which you can use our services. In this case we process your personal data to the extent, for the purpose and for the reason (legal ground) specified here:

Purpose Scope of processed data Legal grounds Period of processing
Registration of user, management and administration of user profile. First name, surname, date of birth, address, e-mail address, phone number, IP address, user ID, numbers and data on the relevant taxi driver licences and certificates, taxi driver’s car registration plate Necessary for performance of contract, or for implementation of measures adopted before the entry into contract during your application for registration Until cancellation of registration by user, however, at the maximum for 3 years from the last login.

For you the statement of these personal data for the purposes of user registration, management and administration of the user profile is entirely voluntary, nevertheless, without these data we are not able to perform the account registration.

  • Inserting photo (passenger portrait) in the user profile

Inserting your photo in your user profile is entirely optional. In this case we process your personal data to the extent, for the purpose and for the reason (legal ground) specified here:

Purpose Scope of processed data Legal grounds Period of processing
Recognition for provision of service. Portrait photo Consent for processing of personal data Until withdrawal of consent for personal data processing or until erasure of these data by user in his or her user profile.

For you the statement of these personal data is entirely voluntary. You always have the right to withdraw your consent for the processing of personal data in the manner specified below in par. 4.2.

  • Use of LIFTAGO application by driver

We process your personal data that you have provided to us during the registration and use of the LIFTAGO application and some other data concerning you specified in the table below to the extent, for the purpose and for the reason (legal ground) specified here:

Purpose Scope of processed data Legal grounds Period of processing
Provision of LIFTAGO services. First name, surname, date of birth, address, e-mail address, phone number, IP address, user ID, numbers and data on the relevant taxi driver licences and certificates, taxi driver’s car registration plate, localization data (GPS coordinates for the time from ordering the service to the end of the ride), information on mobile phone type Necessary for performance of contract. Localization data (GPS coordinates for the time from ordering the service to the end of the ride), information on mobile phone type For 3 years from the last provision of the LIFTAGO service.
First name, surname, date of birth, address, e-mail address, phone number, IP address, user ID, numbers and data on the relevant taxi driver licences and certificates, taxi driver’s car number plate, For 3 years from the expiry of contract.
Basic data on legal relationship and its existence (first name, surname, contact data). For 10 years from the expiry of contract.

If you decide to use the LIFTAGO services, these data are necessary for us to be able to handle your service order and on the basis of this order procure for you a customer for the service.

  • Sending product and service offers and tailor-made offers

We want to stay in contact with you. To that end we process your personal data to the extent, for the purpose and for the reason (legal ground) specified here:

Purpose Rozsah zpracovávaných informací Právní titul Doba zpracování
Sending our product and service offers and tailor-made offers.

 

First name, surname, e-mail address, phone number, user ID assigned by us, localization data (GPS coordinates for the time from ordering the service to the end of the ride) Legitimate interest in staying in contact with you and send you special offers tailored to your needs. For the duration of the legitimate interest, however, at the maximum for 3 years from the last use of the LIFTAGO services.

We will appreciate if we stay in contact so that we can send you our customized product and service offers. To avoid sending you offers you are not interested in, we use the information on the LIFTAGO service that you use. However, we do not want to cause you any inconvenience therefore you have the opportunity to refuse the delivery of commercial communications in the manner specified below and in each single commercial communication (see par. 4.9).

You have the right to object to the processing of your personal data for the purposes of sending commercial communications and based on the objection we will stop sending you commercial communications and terminate the processing of your personal data in this context.

  • Sending tailor-made product and service offers of our business partners

We would appreciate if we could send you commercial communications in the form of newsletters and product and service offers of our business partners tailored to your needs. In this case we process your personal data to the extent, for the purpose and for the reason (legal ground) specified here:

Purpose Scope of processed data Legal grounds Period of processing
Sending tailor-made product and service offers of our business partners First name, surname, e-mail address, phone number, user ID assigned by us, localization data (GPS coordinates for the time from ordering the service to the end of the ride) Consent for processing of personal data and sending of commercial communications Until withdrawal of consent for personal data processing and sending of commercial communications

For you the statement of these personal data is entirely voluntary, however, these data are necessary so that we can send you commercial communications with offers of products and other services.

 

To avoid sending you offers you are not interested in, we use the information on the LIFTAGO service that you use.

 

You always have the right to withdraw your consent for the processing of personal data in the manner specified below in par. 4.2.

 

We process your personal data that you have provided to us when purchasing LIFTAGO Credits at https://daruj.liftago.com and some other data concerning you specified in the table below to the extent, for the purpose and for the reason (legal ground) specified here:

Purpose Scope of processed data Legal grounds Period of processing
Provision of LIFTAGO Credit service. First name, surname, phone number, e-mail address, IP address, unidirectional hash of payment card Necessary for performance of contract. For 3 years from the last provision of the LIFTAGO Credit service.

If you decide to use the LIFTAGO Credits service, these data are necessary for us to be able to handle your service order and on the basis of this order enable you the purchase and use of the LIFTAGO Credits.

  • Sending product and service offers and tailor-made offers

We want to stay in contact with you. To that end we process your personal data to the extent, for the purpose and for the reason (legal ground) specified here:

Purpose Scope of processed data Legal grounds Period of processing
Sending LIFTAGO Credits product and service offers.

 

First name, surname, e-mail address, phone number Legitimate interest in staying in contact with you and send you offers tailored to your needs. For the duration of the legitimate interest, however, at the maximum for 3 years from the last use of the LIFTAGO Credits services.

We will appreciate if we stay in contact so that we can send you our customized product and service offers. However, we do not want to cause you any inconvenience therefore you have the opportunity to refuse the delivery of commercial communications in the manner specified below and in each single communication (see par. 4.9).

You have the right to object to the processing of your personal data for the purposes of sending commercial communications and based on the objection we will immediately stop sending you commercial communications and terminate the processing of your personal data in this context.

  • Sending product and service offers and tailor-made offers of our business partners

We would appreciate if we could send you commercial communications containing newsletters and the product and services offers of our partners. In this case we process your personal data to the extent, for the purpose and for the reason (legal ground) specified here:

Purpose Scope of processed data Legal grounds Period of processing
Sending product and service offers and tailor-made offers of our business partners. First name, surname, e-mail address, phone number Consent for processing of personal data and sending of commercial communications. Until withdrawal of consent for personal data processing and sending of commercial communications.

For you the statement of these personal data is entirely voluntary, however, these data are necessary so that we can send you commercial communications with offers of products and other services.

You always have the right to withdraw your consent for the processing of personal data in the manner specified below in par. 4.2.

  • User using the LIFTAGO Business service
    • Use of the LIFTAGO Business service

We process the personal data that you have provided to us during the registration for the LIFTAGO Business service at https://www.liftago.cz/for-business/, https://business.liftago.com/business/sign-up and https://business.liftago.com/business and some other data concerning you specified in the table below to the extent, for the purpose and for the reason (legal ground) specified here:

Purpose Scope of processed data Legal grounds Period of processing
Provision of LIFTAGO Business service. First name, surname, phone number, e-mail address. Necessary for performance of contract. For 3 years from the last provision of the LIFTAGO Business service.

If you decide to use the LIFTAGO Business service, these data are necessary for us to be able to handle your service order and enable you to use the LIFTAGO Business service.

  • Sending product and service offers and tailor-made offers

We want to stay in contact with you. To that end we process your personal data to the extent, for the purpose and for the reason (legal ground) specified here:

Purpose Scope of processed data Legal grounds Period of processing
Sending LIFTAGO Business product and service offers.

 

First name, surname, e-mail address, phone number. Legitimate interest in staying in contact with you and send you offers tailored to your needs. For the duration of the legitimate interest, however, at the maximum for 3 years from the last use of the LIFTAGO Credits services.

We will appreciate if we stay in contact so that we can send you our customized product and service offers. However, we do not want to cause you any inconvenience therefore you have the opportunity to refuse the delivery of commercial communications in the manner specified below and in each single communication (see par. 4.9).

You have the right to object to the processing of your personal data for the purposes of sending commercial communications and based on the objection we will immediately stop sending you commercial communications and terminate the processing of your personal data in this context.

  • Sending product and service offers and tailor-made offers of our business partners

We would appreciate if we could send you commercial communications containing newsletters and the product and services offers of our partners. In this case we process your personal data to the extent, for the purpose and for the reason (legal ground) specified here:

Purpose Scope of processed data Právní titul Doba zpracování
Sending product and service offers and tailor-made offers of our business partners. First name, surname, e-mail address, phone number. Consent for processing of personal data and sending of commercial communications. Until withdrawal of consent for personal data processing and sending of commercial communications.

For you the statement of these personal data is entirely voluntary, however, these data are necessary so that we can send you commercial communications with offers of products and other services.

You always have the right to withdraw your consent for the processing of personal data in the manner specified below in par. 4.2.

  1. To whom do we transfer your personal data?
    • We cannot always exactly say in advance to whom the personal data will have to be provided. Therefore we specify the categories of possible recipients and the reason for which your personal data might be transferred:
Recipient Reason for access
Drivers using the LIFTAGO service so that they can pick you up and carry you to the required destination. Necessary for performance of contract.
Persons operating payment systems for purposes of performing payments, in particular in connection with card payments. Necessary for performance of contract.
Person responsible for our accounting and tax obligations. We need our provider of accounting and tax services, who is in the position of the processor, to keep our accounting books and fulfil our tax obligations.
Person responsible for the operation of the website, the application and our software (computer systems), including persons providing cloud services. We need our software provider, who is in the position of the processor, to service our web pages and ensure the operation of our information systems.
Person responsible for distributing e-mails. A situation may occur in which a third party will be authorized to distribute e-mails containing our product offers to whom we will provide your e-mail address for that purpose.
  • We want to you to know that we will always comply with your right to obtain information about to whom, when and for what purpose your personal data were transferred.

 

  1. What are your rights?
    • Having regard to the fact that the Companies process personal data concerning you, you have certain rights of which we want to inform you in this section. You can exercise all your rights in any manner which suits you and which allows us to verify that it is really you who submits the request (allows us to check you identity) and we will try our best to satisfy your wishes. However, in order to be able to meet your requirements as best as possible, we need to ask you to exercise your rights in writing at service@liftago.com.

 

  • Right to withdraw consent – we process some of your personal data on the ground of your consent. You have the right to withdraw your consent for the processing of your personal data, including the consent for the delivery of commercial communications. You can withdraw your consent by sending a request to service@liftago.com.

As regards the processing of your personal data for the purposes of sending commercial communications, you can withdraw your consent for the processing of your personal data and the consent for the sending of commercial communications simply by clicking on the relevant link which is included at the end of each commercial communication.

  • Right to access – you have the right to access the personal data concerning you that are processed by our company and at the same time the right to information on what personal data concerning you we process, for how long, what the purposes of their processing are, to whom we disclose the data and whether we use them for automatic decision-making (and how such automated decision-making works).

We will give you a copy of your personal data for free. Only if you ask for more copies, we will have to ask you to pay the necessary cost for their issue.

  • Right to rectification – if you find out that we process incomplete or inaccurate personal data, you have the right to demand that we rectify or, if required by the purpose of the processing of the personal data, supplement the personal data.
  • Right to erasure – You also have the right to the erasure of your personal data retained and processed by our company. You may only demand erasure if one of the following reasons is present:
  • your personal data are no longer necessary in relation to the purpose for which they were collected o processed;
  • your personal data have been processed by our company unlawfully;
  • you have withdrawn your consent based on which your personal data were processed; and we do not have any other reason (legal ground) to further process these personal data;
  • you object to the processing of your personal data if these personal data are processed for use in direct marketing (e.g. sending of commercial communications);
  • you object to the processing of your personal data which we process on the basis of our legitimate interest and if we will not be able to demonstrate that our legitimate interest prevails over your right to erasure;
  • there is a statutory reason for which the erasure of these personal data is required;
  • Our company processes the personal data of a child without parent’s consent to such processing.

We need to warn you that a situation may occur when your personal data may not be erased on the ground of your withdrawal of your consent with the processing of the personal data or your request for erasure of the personal data. These are in particular situations when we are required by law to process your personal data. In a situation like this our company will inform you on the reason for which your personal data may not be erased despite your explicit request for the erasure of your personal data.

  • Right to data portability – another right that you may exercise is the right to portability. You have the right to receive the personal data concerning you which you have provided to us on the basis of your consent and which we process by automated means. Upon your request we will give you these personal data that meet these conditions in a commonly used, structured and machine-readable format or, upon your request, transfer them to another controller specified by you if it is technically feasible.

 

  • Right to restriction of processing – whenever you feel that your personal data processed by our company are erroneous, you have the right to demand that we restrict the processing of your personal data for a time necessary to verify the accuracy of your personal data and to rectify the data.

You have this right in the following cases:

  • the processing of your personal data is unlawful but you do not wish that your personal data are erased;
  • our company no longer needs your personal data for the purpose for which we have processed them but you insist on their processing (in particular their retention) by our company for the establishment, exercise or defence of your legal claims;
  • you have objected to the processing of your personal data on the ground of our company’s legitimate interest and the restriction of processing in this case shall be valid for the time necessary to verify whether our legitimate interest overrides your right to demand that your personal data are no longer processed.
    • Right to object to the processing of your personal data on the ground of legitimate interest – with view to the fact that we process some of your personal data on the ground of legitimate interest, you have the right to object to this processing and on the basis of this objection we will assess whether the processing of your personal data actually is in our legitimate interest or whether preference should be given to your right to demand that your personal data are no longer processed.

 

  • Right to object to the processing of your personal data for direct marketing purposes – you have the right to object to our processing of your personal data for the purposes of direct marketing (e.g. sending of commercial communications). In such case we will automatically cease to process your personal data for this purpose.

 

  • Right to complain – in the event that you find all of the above-described rights insufficient or if you are of the opinion that our company in any way violates your rights, you have the opportunity to file a complaint with the supervisory office. You may file your complaint to the Office for Personal Data Protection via the contacts that are available at https://www.uoou.cz/podatelna-uradu/os-1006.

4.11     Data protection officer – you can contact our data protection officer at dpo@liftago.com.