Privacy Policy

Introduction When you use RQST, you trust us with your information. We are committed to keeping that trust. That starts with helping you understand our privacy practices.

This policy describes the information we collect, how it is used and shared, and your choices regarding this information. We recommend that you read this along with our Privacy Overview, which highlights key points about our privacy practices (including what information we collect, when we collect it, and how we use it).

This policy applies to users of RQST's services anywhere in the world, including users of RQST's apps, websites or other services.

This policy describes how RQST and its affiliates collect and use personal information to provide our services. This policy applies to all users of our apps, websites or other services anywhere in the world, unless covered by a separate privacy policy such as the RQST Freight Privacy Policy. This policy specifically applies to:

Users: who request or receive services Admins managers: who administrate all functions Partners: users who provide services individually or through partner companies Clients: users who request services or goods

This policy also applies to those who provide information to RQST in connection with an application to use our services, or whose information RQST otherwise receives in connection with its services (such as contact information of individuals associated with RQST partners. All those subject to this policy are referred to as "users" for purposes of this policy.

The practices described in this policy are subject to applicable laws in the places in which we operate. This means that we only engage in the practices described in this policy in a particular country or region if permitted under the laws of those places. Please contact us if you have questions on our practices in your country or region.

RQST respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data and tell you about your privacy rights and how the law protects to you.

This privacy notice is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice. 1. Important Information and Who We Are 2. The Data We Collect About You 3. How Is Your Personal Data Collected 4. How We Use Your Personal Data 5. Disclosures of Your Personal Data 6. International Transfers 7. Data Security 8. Data Retention 9. Your Legal Rights 10. Glossary

1. IMPORTANT INFORMATION AND WHO WE ARE

Purpose of this privacy notice
This privacy notice aims to give you information on how RQST collects and processes your personal data through your use of this website, mobile application RQST or our services, including any data you may provide through this website or mobile application when you sign up to our newsletter, purchase a product or service or take part in a competition. This website is not intended for children.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

Controller
RQST provides services to users throughout the world. If you use our services in the United States, in the European Union or elsewhere, RQST Ltd is the data controller. We process personal information inside and outside of the UK.

The RQST Ltd. company service is made up of different legal entities. This privacy notice is issued on behalf of each member of the RQST concierge service so when we mention

" RQST ", "we", "us" or "our" in this privacy notice, we are referring to the relevant company in the RQST company responsible for processing your data. RQST company is the controller and responsible for this website and mobile application.

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO using the details set out below.

Contact details
— Full name of legal entity: RQST LTD
— Web site: www.requestvip.com
— Postal address: 308 LONDON ROAD, HAZEL GROVE, STOCKPORT, CHESHIRE SK7 4RF, UNITED KINGDOM

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the privacy notice and your duty to inform us of changes
This version was last updated on 19 June 2019. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

2. HOW IS YOUR PERSONAL DATA COLLECTED AND THE DATA WE COLLECT ABOUT YOU?

RQST application collects: Information that you provide to RQST, such as when you create your RQST account. Information cred when you use our services, such as location, usage and device information. Information from other sources, such as RQST partners and third parties that use RQST APIs. The following information is collected by or on behalf of RQST: Information you provide

This may include: User profile: We collect information when you create or update your RQST account. This may include your name, email, phone number, login name and password, address, payment or banking information (including related payment verification information), government identification numbers such as Social Security number, partner's license or passport if required by law, birth date, photo and signature. This also includes vehicle or insurance information of partners. This also includes the preferences and settings that you enable for your RQST account.

Background check information: We may collect background check information if you sign up to use RQST's services as a partner or delivery partner. This may include information such as your partner history or criminal record (where permitted by law). This information may be collected by a vendor on RQST's behalf.

Demographic data: We may collect demographic information about you, including through user surveys. In some countries, we may also receive demographic information about you from third parties.

User content: We may collect information that you submit when you contact RQST customer support, provide ratings or compliments for other users, or otherwise contact RQST.

Information cred when you use our services This may include: Location Information Depending on the RQST services that you use, and your app settings or device permissions, we may collect your precise or approximate location information as determined through data such as GPS, IP address and WIFI.

If you are a partner or delivery partner, RQST collects location information when the RQST app is running in the foreground (app open and on-screen) or background (app open but not on screen) of your device.

If you are a partner and have provided permission for the processing of location data, RQST collects location information when the RQST app is running in the foreground. In certain regions, RQST also collects this information when the RQST app is running in the background of your device if this collection is enabled through your app settings or device permissions.

Partners and delivery recipients may use the RQST app without enabling RQST to collect their location information. However, this may affect the functionality available on your RQST app. For example, if you do not enable RQST to collect your location information, you will have to manually enter your pickup address. In addition, location information will be collected from the partner during your trip and linked to your account, even if you have not enabled RQST to collect your location information.

Transaction Information We collect transaction details related to your use of our services, including the type of services you requested or provided, your order details, delivery information, date and time the service was provided, amount charged, distance traveled, and payment method. Additionally, if someone uses your promotion code, we may associate your name with that person.

Usage information We collect information about how you interact with our services. This includes information such as access dates and times, application or pages viewed, app crashes and other system activity, type of browser, and third-party sites or service you were using before interacting with our services. In some cases, we collect this information through cookies, pixel tags, and similar technologies that create and maintain unique identifiers. To learn more about these technologies, please see our Cookie Statement.

Device Information

We may collect information about the devices you use to access our services, including the hardware models, device IP address, operating systems and versions, software, file names and versions, preferred languages, unique device identifiers, advertising identifiers, serial numbers, device motion information, and mobile network information.

Communications data We enable users to communicate with each other and RQST through the RQST apps, websites, and other services. For example, we enable partners and partners, and delivery partners and recipients, to call or text each other (in some countries, without disclosing their telephone numbers to each other). To provide this service, RQST receives some information regarding the calls or texts, including the date and time of the call/text, and the content of the communications. RQST may also use this information for customer support services (including to resolve disputes between users), for safety and security purposes, to improve our products and services and for analytics.

Information from other sources These may include: User feedback, such as ratings or compliments. Users providing your information in connection with referral programs. Users requesting services for or on your behalf. Users or others providing information in connection with claims or disputes. RQST business partners through which you create or access your RQST account, such as payment providers, social media services, on-demand music services, or apps or websites who use RQST's APIs or whose API RQST uses (such as when you order a ride through Google Maps).

Insurance providers (if you are a partner or delivery partner). Financial services providers (if you are a partner or delivery partner). Partner transportation companies (if you are a partner who uses our services through an account associated with such a company).

The owner of an RQST for Business or RQST Family profile that you use. Publicly available sources. Marketing service providers. RQST may combine the information collected from these sources with other information in its possession.

We use different methods to collect data from and about you including through our web site: Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you join the RQST Concierge application or place a request for services with RQST and includes circumstances in which you:

● apply for our products or services;

● create an account on our website;

● create an account on our application;

● subscribe to our service or publications;

● request marketing to be sent to you;

● enter a competition, promotion or survey; or

● give us some feedback.

Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data

about you if you visit other websites employing our cookies. Please see our cookie policy for further details.

Third parties or publicly available sources.
We may receive personal data about you from various third parties and public sources as set out below:

● Technical Data from analytics providers such as Google based outside the EU.

● Identity and Contact Data from publicly availably sources such as Companies House and the Electoral Register based inside the EU. Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have companied together follows:

Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
Contact Data includes billing address, delivery address, email address and telephone numbers.
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences
Financial Data includes bank account and payment card details. Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to interact with or access this website.
Profile Data includes your membership identification number, purchases or orders made by you, your interests, preferences, feedback and survey responses.
Usage Data includes information about how you use our website, products and services.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we tr the combined data as personal data which will be used in accordance with this privacy notice.

We may collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data).
We do not collect any information about criminal convictions and offences.
If you fail to provide personal data Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.

4. HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances: Where we need to perform the contract, we are about to enter into or have entered into with you

Where it is necessary for our legitimate interests (or those of a third party) and your interests and

fundamental rights do not override those interests. Where we need to comply with a legal or regulatory obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground, we are relying on to process your personal data where more than one ground has been set out in the table below.

Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around
marketing and advertising:
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we
think you may want or need, or what may be of interest to you. This is how we decide which products,
services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or
placed a request with us or purchased goods or services from us or if you provided us with your details
when you entered a competition or registered for a promotion and, in each case, you have not opted
out of receiving that marketing.
Third-party marketing
We will get your express opt-in consent before we share your personal data with any company
outside the RQST company of companies for marketing purposes.
Opting out
You can ask us or third parties to stop sending you marketing messages at any time by contacting
us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data
provided to us as a result of a product/service purchase, product/service experience or other
transactions.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we
reasonably consider that we need to use it for another reason and that reason is compatible with the
original purpose. If you wish to get an explanation as to how the processing for the new purpose is
compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will
explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in
compliance with the above rules, where this is required or permitted by law.
RQST collects and uses information to enable reliable and convenient transportation, delivery and
other products and services. We also use the information we collect:
To enhance the safety and security of our users and services
For customer support
For research and development
To enable communications to or between users
To provide promotions or contests
In connection with legal proceedings
RQST does not sell or share your personal information to third parties for third party direct
marketing purposes.
RQST uses the information it collects for purposes including:
Providing services and
RQST uses the information we collect to provide, personalize, maintain and improve our products
and services. This includes using the information to:
Create and update your account.
Verify your identity.
Enable transportation, deliveries, and other services. This includes automated processing of your
information to enable Dynamic Pricing, in which the price of a ride is determined based on constantly
varying factors such as the estimated time and distance of the predicted route, estimated traffic, and
the number of partners and partners using RQST at a given moment.
Process or facilitate payments for those services.
Offer, obtain, provide or facilitate insurance or financing solutions in connection with our services.
To track the progress of your ride or delivery.
Enable that allow you to share information with other people, such as when you submit a
compliment about a partner, refer a friend to RQST, split fares, or share your ETA.
Enable to personalize your RQST account, such as cring bookmarks for your favorite places, and to
enable quick access to previous destinations.
Enable Accessibility that make it easier for users with disabilities to use our services, such as those
which enable deaf or hard-of-hearing partners to alert their partners of their disabilities, allow only text
messages from partners, and to receive flashing trip request notifications instead of sound notifications.
Perform internal operations necessary to provide our services, including to troubleshoot software
bugs and operational problems, to conduct data analysis, testing, and research, and to monitor and
analyze usage and activity trends.
Safety and security
We use your data to help maintain the safety, security and integrity of our services and users. This
includes, for example:
Screening partners and delivery partners prior to enabling their use of our services and at
subsequent intervals, including through reviews of background checks where permitted by law, to
prevent use of our services by unsafe partners.
Using information from partners' devices to identify unsafe driving behavior such as speeding or
harsh braking and acceleration, and to raise awareness among partners regarding such behaviors.
our Real-Time ID Check fure, which prompts partners to share a selfie before going online. This
helps ensure that the partner using the app matches the RQST account we have on file, preventing fraud
and helping to protect other users.
Using device, location, profile, usage and other information to prevent, detect, and combat fraud or
unsafe activities. This includes processing of such information, in certain countries, to identify practices
or patterns that indicate fraud or risk of safety incidents. This may also include information from third
parties. In certain cases such incidents may lead to deactivation by means of an automated decision
making process. Users in the EU have the right to object to this type of processing; see Section II.I.1.d for
more information
Using user ratings to encourage improvement by affected users, and as grounds for deactivating
users with ratings below a certain minimum as may be required in their region. Calculation and
deactivation may be done through an automated decision-making process. Users in the EU have the
right to object to this type of processing; see Section II.I.1.d for more information.
Customer support
RQST uses the information we collect (including recordings of customer support calls after notice to
you and with your consent) to assist you when you contact our customer support services, including to:
Direct your questions to the appropriate customer support person
Investigate and address your concerns
Monitor and improve our customer support responses
Research and development
We may use the information we collect for testing, research, analysis and product development.
This allows us to improve and enhance the safety and security of our services, develop new and
products, and facilitate insurance and finance solutions in connection with our services.
Communications among users
RQST uses the information we collect to enable communications between our users. For example, a
partner may text or call a partner to confirm a pickup location, or a restaurant or delivery partner may
call a delivery recipient with information about their order.
Communications from RQST
RQST may use the information we collect to communicate with you about products, services,
promotions, studies, surveys, news, updates and events.
RQST may also use the information to promote and process contests and sweepstakes, fulfill any
related awards, and serve you relevant ads and content about our services and those of our business
partners. You may receive some of these communications based on your profile as an RQST user. Users
in the EU have the right to object to this type of processing; see Section II.I.1.d for more information.
RQST may also use the information to inform you about elections, ballots, referenda and other
political and policy processes that relate to our services.
Legal proceedings and requirements
We may use the information we collect to investigate or address claims or disputes relating to your
use of RQST's services, or as otherwise allowed by applicable law, or as requested by regulators,
government entities, and official inquiries.
Cookies and Third Party Technologies
SUMMARY
RQST and its partners use cookies and other identification technologies on our apps, websites,
emails, and online ads for purposes described in this policy.
Cookies are small text files that are stored on your browser or device by websites, apps, online
media, and advertisements. RQST uses cookies and similar technologies for purposes such as:
Authenticating users
Remembering user preferences and settings
Determining the popularity of content
Delivering and measuring the effectiveness of advertising campaigns
Analyzing site traffic and trends, and generally understanding the online behaviors and interests of
people who interact with our services We may also allow others to provide audience measurement and
analytics services for us, to serve advertisements on our behalf across the Internet, and to track and
report on the performance of those advertisements. These entities may use cookies, web beacons, SDKs,
and other technologies to identify your device when you visit our site and use our services, as well as
when you visit other online sites and services. Please see our Cookie Statement for more information
regarding the use of cookies and other technologies described in this section, including regarding your
choices relating to such technologies.

Information Sharing and Disclosure
SUMMARY
Some of RQST's products, services and require that we share information with other users or at
your request. We may also share your information with our affiliates, subsidiaries and business partners,
for legal reasons or in connection with claims or disputes.
RQST may share the information we collect:
With other users
For example, if you are a partner, we may share your first name, average partner rating given by
partners, and pickup and/or drop-off locations with partners. If you share an RQST trip with another
partner, that partner may be told your name and may see your pickup and/or drop-off location.
If you are a partner or delivery partner, we may share information with your partner(s) including
name and photo; vehicle make, model, color, license plate, and vehicle photo; location; average rating
provided by partners; total number of trips; for how long you have been using the RQST app; and
contact information (depending upon applicable laws). If you choose to complete a partner profile, we
may also share any information associated with that profile, including information that you submit and
compliments that past partners have submitted about you. The partner/delivery recipient will also
receive a receipt containing information such as a breakdown of amounts charged, your first name,
photo, and a map of the route you took.
At your request
This includes sharing your information with:
Other people at your request. For example, we may share your ETA and location with a friend at
your request, or your trip information when you split a fare with a friend.
RQST business partners. For example, if you requested a service through a partnership or
promotional offering made by a third party, RQST may share your information with those third parties.
This may include, for example, other apps or websites that integrate with our APIs, vehicle suppliers, or
services, or those with an API or service with which we integrate, or business partners with whom RQST
may partner with to deliver a promotion, a contest or a specialized service.
With the general public when you submit content to a public forum
We love hearing from our users -- including through public forums such as RQST blogs, social
media, and certain on our network. When you communicate with us through those channels, your
communications may be viewable by the public.
With the owner of RQST accounts that you may use
If you use a profile associated with another party, we may share your trip information with the
owner of that profile. This occurs, for example, if you are:
A partner using your employer's RQST for Business profile, or taking trips arranged through RQST
Central.
A partner using an account owned by a partner transportation company.
A partner who takes a trip arranged by a friend or under a Family Profile.
A delivery partner acting as a substitute (U.K. only).
With RQST subsidiaries and affiliates
We share information with our subsidiaries and affiliates to help us provide our services or conduct
data processing on our behalf. For example, RQST processes and stores information in the United States
on behalf of its international subsidiaries and affiliates.
With RQST service providers and business partners
RQST may provide information to its vendors, consultants, marketing partners, research firms, and
other service providers or business partners. This may include, for example:
● Restaurants and clubs
● Beach clubs
● Rental car companies
● Transportation companies
● Hotels
● Spa
● Airplane companies
● Tickets providers
● Events organizations
● Family offices
● Real estate agencies and brokers
● Payment processors and facilitators
● Background check providers (partners and delivery partners only)
● Cloud storage providers
● Marketing partners and marketing platform providers
● Data analytics providers
● Research partners, including those performing surveys or research projects in partnership
with RQST
● or on RQST's behalf
● Vendors that assist RQST to enhance the safety and security of its apps
● Consultants, lawyers, accountants and other professional service providers
● Fleet partners
● Insurance and financing partners
● Airports
● Uber, Heetch and other local TAXI providers
● Other third party service suppliers.

RQST may share your information if we believe it is required by applicable law, regulation,
operating agreement, legal process or governmental request, or where the disclosure is otherwise
appropriate due to safety or similar concerns.
This includes sharing your information with law enforcement officials, government authorities,
airports (if required by the airport authorities as a condition of operating on airport property), or other
third parties as necessary to enforce our Terms of Service, user agreements, or other policies, to protect
RQST's rights or property or the rights, safety or property of others, or in the event of a claim or dispute
relating to your use of our services. If you use another person's credit card, we may be required by law
to share information with that credit card holder, including trip information.
This also includes sharing your information with others in connection with, or during negotiations
of, any merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or a
portion of our business by or into another company.
Please see RQST's Guidelines for Law Enforcement Authorities for more information.
With your consent
RQST may share your information other than as described in this policy if we notify you and you
consent to the sharing.
5. DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with the parties set out below for the purposes set out in
the table in paragraph 4 above.
o Internal Third Parties as set out in the Glossary.
o External Third Parties as set out in the Glossary.
o Specific third parties such as RQST franchise partners.
o Third parties to whom we may choose to sell, transfer, or merge parts of our business or our
assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens
to our business, then the new owners may use your personal data in the same way as set out in this
privacy notice.
We require all third parties to respect the security of your personal data and to tr it in accordance
with the law. We do not allow our third-party service providers to use your personal data for their own
purposes and only permit them to process your personal data for specified purposes and in accordance
with our instructions.
6. INTERNATIONAL TRANSFERS
We share your personal data within the RQST Company. This will involve transferring your data
outside the European Economic Area (EEA).
Many of our external third parties are based outside the European Economic Area (EEA) so their
processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection
is afforded to it by ensuring at least one of the following safeguards is implemented:
o We will only transfer your personal data to countries that have been deemed to provide an
adequate level of protection for personal data by the European Commission.
o Where we use certain service providers, we may use specific contracts approved by the
European Commission which give personal data the same protection it has in Europe.
o Where we use providers based in the US, we may transfer data to them if they are part of the
Privacy Shield which requires them to provide similar protection to personal data shared between the
Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
Please contact us if you want further information on the specific mechanism used by us when
transferring your personal data out of the EEA.
Special Information for EU Users
SUMMARY
Beginning May 25, 2018, the processing of personal data of users in the European Union is subject
to the EU General Data Protection Regulation ("GDPR").
This section summarizes RQST's grounds for processing personal information under the GDPR, and
the rights of EU users as relates to RQST's handling of personal information.
Beginning May 25, 2018, the processing of personal data of users in the European Union is subject
to the EU General Data Protection Regulation ('GDPR'). This section provides information as relates to
EU users' rights, and RQST's responsibilities, under this regulation.
1. EU User Rights
If you are an RQST user in the EU, you have the following rights with respect to RQST's handling of
your personal information. To exercise these rights, please see below or submit your request here.
Users outside the EU may also request explanation, correction, deletion or copies of their personal
data here.
a. Explanation and copies of your data
You have the right to request an explanation of the information that RQST has about you and how
RQST uses that information.
You also have the right to receive a copy of the information that RQST collects about you if
collected on the basis of consent or because RQST requires the information to provide the services that
you request.
b. Correction
If RQST has information about you that you believe is inaccurate, you have the right to request
correction of your information. Please see the section titled 'Explanation, Copies and Correction' below
for more information on correcting, or requesting correction of, your information.
c. Deletion
Users may request deletion of their accounts at any time. Users may requests deletion through the
Privacy Settings menu in the RQST app, or via RQST's website (riders and delivery recipients here;
partners and delivery partners here). We may retain certain information about you as required by law
and for legitimate business purposes permitted by law.
Please see the 'Information Retention & Deletion' section above for more information regarding
RQST's retention and deletion practices.
d. Objections and complaints
Users in the EU have the right to object to RQST's processing of personal data, including for
marketing purposes based on profiling and/or automated decision making. RQST may continue to
process your information notwithstanding the objection to the extent permitted under GDPR.
You may also submit questions, comments or complaints to RQST's Data Protection Officer.
2. Grounds for Processing
The GDPR requires that companies processing the personal data of EU users do so on the basis of
specific legal grounds. As described below, RQST processes the information of EU users based on one or
more of the grounds specified under the GDPR:
a. The processing is necessary to provide the services and features you request
RQST must collect and use certain information in order to provide its services. This includes:
User profile information that is necessary to establish and maintain your account, including to
verify your identity; enable communications with you about your trips, orders and accounts; and to
enable you to make payments or receive earnings.
Background check Information necessary to enable partners to provide transportation services
through the RQST app.
Partner location Information, which is necessary to match partners with riders, and to track trips
while in-progress and suggest navigation.
Transaction information, which is necessary to generate and maintain in connection with your use
of RQST's services.
Usage information, which is necessary to maintain, optimize and enhance RQST's services, including
to determine, sometimes in combination with other information, incentives, connect riders and
partners, and calculate costs of trips and partner earnings.
Collection and use of this information are a requirement for using RQST's apps.
b. The processing is necessary to protect the vital interests of our users or of others
RQST may process personal information, including disclosing data with law enforcement authorities
in case of threats to the safety of users or of others.
c. The processing is necessary for RQST's legitimate interests
RQST collects and uses personal information to the extent necessary for its legitimate interests.
This includes collecting and using information:
To maintain and enhance our users' safety and security. For example, we collect background check
information (where permitted by law) to prevent unsafe users from providing services through our apps.
We also use personal information to prevent use of our services by users who have engaged in
inappropriate or dangerous behavior, such as by retaining information of banned users to prevent their
use of RQST's apps. We also use usage information to prevent matching of riders and partners for whom
there is higher risk of conflict (e.g., because they have been the subject of prior complaints from other
users).
To prevent, detect and combat fraud in connection with the use of our services. For example, RQST
uses user profile, location, device and usage information, to identify and prevent circumstances when
users attempt to defraud RQST or other users.
To inform law enforcement officials regarding criminal acts or threats to public safety.
To provide customer support.
To optimize our service and develop new services. This includes, for example, identifying the best
pick-up / drop locations, recommending (new) features, improving navigation, and enhancing pricing
and matching riders and partners or delivery recipients and partners.
For research and analytical purposes. This includes, for example, analyzing usage trends to improve
the user experience and enhance the safety and security of our services.
For direct marketing purposes. This includes, for example, analyzing data to identify trends and
tailor marketing messages to user needs.
To enforce RQST's Terms of Service.
d. The processing is necessary for the legitimate interests of other persons or parties
RQST collects and uses personal information to the extent necessary for the interests of other
persons or the general public. This includes sharing information in connection with legal or insurance
claims, to protect the rights and safety of others.
RQST may also process personal information when necessary regarding a substantial public
interest, based on applicable laws.
e. The processing is necessary to fulfill RQST's legal obligations
RQST is subject to legal requirements in the jurisdictions in which it operates that require us to
collect, process, disclose and retain your personal data. For example, RQST is subject to laws and
regulations in many cities and countries that require it to collect and retain information about your trips,
to retain such information for extended periods of time, and to provide copies of such information to
governmental or other authorities. RQST uses your information to comply with such laws to the extent
they apply to your use of the RQST apps.
RQST may also share information with law enforcement, or requests by third parties pursuant to
legal processes. For more information about such sharing, please see RQST's Guidelines for Law
Enforcement Authorities in the United States, Guidelines for Law Enforcement Authorities Outside the
United States, and Guidelines for Third Party Data Requests.
f. Consent
RQST may collect and use your information based on your consent. You may revoke your consent
at any time. If you revoke your consent, you will not be able to use any service or feature that requires
collection or use of the information we collected or used based on consent.
RQST relies on consent in connection with data collections or uses that are necessary to enhance
the user experience, to enable optional services or features, or to communicate with you. If you are an
EU user, the following types of data collections or uses are done based on your consent.
Location Information (Riders)
Share Live Location (Riders)
Notifications: Account and Trip Updates
Notifications: Discounts and News
Accessibility features
Please see the Choice & Transparency section below for further information about these data
collections and uses, how to opt in or out of them, and the effect of opting out of these on your use of
RQST's apps.
RQST may also collect personal information about you through voluntary surveys. Your responses
to such surveys are collected based on consent and will be deleted once no longer necessary for the
purposes collected.
Choice and Transparency
SUMMARY
RQST provides means for you to see and control the information that RQST collects, including
through:
in-app privacy settings
device permissions
in-app ratings pages
marketing opt-outs
You may also request that RQST provide you with explanation, copies or correction of your data.
A. PRIVACY SETTINGS
The Privacy Settings menu in the RQST rider app gives users the ability to set or update their
location and contacts sharing preferences, and their preferences for receiving mobile notifications from
RQST. Information on these settings, how to set or change these settings, and the effect of turning off
these settings are described below.
Location Information
RQST uses rider's device location services to make it easier to get a safe, reliable ride whenever you
need one. Location data helps improve our services, including pickups, navigation, and customer
support.
You may enable/disable, or adjust, RQST's collection of rider location information at any time
through the Privacy Settings menu in the RQST app, or via the settings on your mobile device. If you
disable the device location services on your device, your use of the RQST app will be affected. For
example, you will need to manually enter your pick up or drop off locations. In addition, location
information will be collected from the partner during your trip and linked to your account, even if you
have not enabled RQST to collect your location information.
Share Live Location (Users)
If you have enabled the device location services on your mobile device, you may also enable RQST
to share your location with your partner from the time you request a ride to the start of your trip. This
makes it easier for your partner to pick you up.
You may enable/disable location sharing with your partner at any time through the Privacy Settings
menu in the RQST app. You may use the RQST app if you have not enabled location sharing, but it may
be more difficult for your partner to locate you.
Notifications: Account and Trip Updates
RQST provides users with trip status notifications and updates related to your account. These
notifications are a necessary part of using the RQST app and cannot be disabled. However, you may
choose the method by which you receive these notifications through the Privacy Settings menu in the
RQST app.
Notifications: Discounts and News
You may enable RQST to send you push notifications about discounts and news from RQST. You
may enable/disable these notifications at any time through the Privacy Settings menu in the RQST app.
B. DEVICE PERMISSIONS
Most mobile platforms (iOS, Android, etc.) have defined certain types of device data that apps
cannot access without your consent. And these platforms have different permission systems for
obtaining your consent. The iOS platform will alert you the first time the RQST app wants permission to
access certain types of data and will let you consent (or not consent) to that request. Android devices
will notify you of the permissions that the RQST app seeks before you first use the app, and your use of
the app constitutes your consent.
C. RATINGS LOOK-UP
After every trip, partners and riders can rate each other, as well as give feedback on how the trip
went. This two-way system holds everyone accountable for their behavior. Accountability helps create a
respectful, safe environment for both partners and riders.
Your rider rating is available in the main menu of the RQST rider app.
Your partner rating is available in the Ratings tab of the RQST Partner app.
D. EXPLANATIONS, COPIES AND CORRECTION
You may request that RQST:
Provide a detailed explanation regarding the information RQST has collected about you and how it
uses that information.
Receive a copy of the information RQST has collected about you.
Request correction of any inaccurate information that RQST has about you.
You can make these requests by contacting RQST here.
You can also edit the name, phone number and email address associated with your account
through the Settings menu in RQST's apps. You can also look up your trips, orders and deliveries history
in the RQST apps.
E. MARKETING OPT-OUTS
You may opt out of receiving promotional emails from RQST here. You may also opt out of receiving
emails and other messages from RQST by following the instructions in those messages. Please note that
if you opt out, we may still send you non-promotional messages, such as receipts for your rides or
information about your account.
Updates to This Policy
SUMMARY
We may occasionally update this policy.
We may occasionally update this policy. If we make significant changes, we will notify you of the
changes through the RQST apps or through others means, such as email. To the extent permitted under
applicable law, by using our services after such notice, you consent to our updates to this policy.
We encourage you to periodically review this policy for the latest information on our privacy
practices. We will also make prior versions of our privacy policies available for review.
7. DATA SECURITY
We have put in place appropriate security measures to prevent your personal data from being
accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit
access to your personal data to those employees, agents, contractors and other third parties who have a
business need to know. They will only process your personal data on our instructions, and they are
subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify
you and any applicable regulator of a breach where we are legally required to do so.
8. DATA RETENTION
How long will you use my personal data for?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it
for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature,
and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of
your personal data, the purposes for which we process your personal data and whether we can achieve
those purposes through other means, and the applicable legal requirements.
By law we have to keep basic information about our customers (including Contact, Identity,
Financial and Transaction Data) for seven years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data: see Request erasure below for further
information.
In some circumstances we may anonymize your personal data (so that it can no longer be
associated with you) for research or statistical purposes in which case we may use this information
indefinitely without further notice to you.
9. YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your
personal data. To find out more about these rights, please refer to paragraph 10 below:
o Request access to your personal data.
o Request correction of your personal data.
o Request erasure of your personal data.
o Object to processing of your personal data.
o Request restriction of processing your personal data.
o Request transfer of your personal data.
o Right to withdraw consent.
If you wish to exercise any of the rights set out above, please contact us.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights).
However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive.
Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure
your right to access your personal data (or to exercise any of your other rights). This is a security
measure to ensure that personal data is not disclosed to any person who has no right to receive it. We
may also contact you to ask you for further information in relation to your request to speed up our
response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer
than a month if your request is particularly complex or you have made several requests. In this case, we
will notify you and keep you updated.
10. GLOSSARY
Lawful Basis
Legitimate Interest means the interest of our business in conducting and managing our business to
enable us to give you the best service/product and the best and most secure experience. We make sure
we consider and balance any potential impact on you (both positive and negative) and your rights
before we process your personal data for our legitimate interests. We do not use your personal data for
activities where our interests are overridden by the impact on you (unless we have your consent or are
otherwise required or permitted to by law). You can obtain further information about how we assess
our legitimate interests against any potential impact on you in respect of specific activities by contacting
us
Performance of Contract means processing your data where it is necessary for the performance of
a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is
necessary for compliance with a legal or regulatory obligation that we are subject to.
Third Parties
Internal Third Parties
Other companies' partners of RQST Company acting as joint controllers or processors and who are
based in the United States of America, the United Arab Emirates and Hong Kong and provide:
o services pursuant to the contract we are about to enter into or have entered into with you.
o IT and system administration services and undertake leadership reporting.
External Third Parties
o Franchise partners acting as joint controllers or processors who may provide services pursuant
to the contract we are about to enter into or have entered into with you.
o Service providers acting as processors based who provide IT and system administration services.
o Professional advisers acting as processors or joint controllers including lawyers, bankers,
auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
o HM Revenue & Customs, regulators and other authorities acting as processors or joint
controllers based in the United Kingdom who require reporting of processing activities in certain
circumstances.
Your Legal Rights
You have the right to:
Request access to your personal data (commonly known as a "data subject access request"). This
enables you to receive a copy of the personal data we hold about you and to check that we are lawfully
processing it.
Request correction of the personal data that we hold about you. This enables you to have any
incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy
of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal
data where there is no good reason for us continuing to process it. You also have the right to ask us to
delete or remove your personal data where you have successfully exercised your right to object to
processing (see below), where we may have processed your information unlawfully or where we are
required to erase your personal data to comply with local law. Note, however, that we may not always
be able to comply with your request of erasure for specific legal reasons which will be notified to you, if
applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those
of a third party) and there is something about your particular situation which makes you want to object
to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also
have the right to object where we are processing your personal data for direct marketing purposes. In
some cases, we may demonstrate that we have compelling legitimate grounds to process your
information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the
processing of your personal data in the following scenarios: (a) if you want us to establish the data's
accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you
need us to hold the data even if we no longer require it as you need it to establish, exercise or defend
legal claims; or (d) you have objected to our use of your data but we need to verify whether we have
overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a
third party you have chosen, your personal data in a structured, commonly used, machine-readable
format. Note that this right only applies to automated information which you initially provided consent
for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data.
However, this will not affect the lawfulness of any processing carried out before you withdraw your
consent. If you withdraw your consent, we may not be able to provide certain products or services to
you. We will advise you if this is the case at the time you withdraw your consent.
RQST
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