Privacy Policy

TRANSFERGEST’S PRIVACY POLICY FOR USERS IN PORTUGAL

1. What is this Privacy Policy for?

At Transfergest we are committed to providing optimum service, facilitating your urban and interurban travel in conditions of maximum quality, comfort and respect for the urban environment and the environment. In addition, we are also concerned about the privacy of your personal information. We want you to know and have control over your data at all times. To this end, we have made available to you this Privacy Policy (the “Privacy Policy”), in which you can consult in detail, but easily and transparently, the characteristics of the use we make of your data to be able to provide our Service and for other purposes.

You may access this Privacy Policy at any time, as it is available to you in the “Privacy Policy” section of the Transfergest website (www.transfergest.com) and in the Transfergest Mobile App. On the website, the “Privacy Policy” point is located at the bottom of each page, while on the App it is accessible from the menu that you can unfold by clicking on the circle located at the top left of the screen. When we use the term “Platform”, we refer to both the Website and the Application. To refer to all the above information and any other information we have about you, we will use the term “Personal Data” from now on.

2. Who is responsible for the processing of your personal data?

The Responsible for the treatment of your Personal Data is Transfergest. You can find more information about us at:

OSB Solutions, Unipessoal lda

Postal Address: Rua General Humberto Delgado, nº6, 2ºEsq. 1495-067 Algés.

The Transfergest Software is developed by OSB Solutions, Unipessoal Lda. This means that both parties decide how they use and protect the Personal Data of users. Transfergest’s roles and responsibilities in using and protecting your Data are clearly defined in an agreement.

3. Where do we get your Personal Data? What data do we use?

Please note that for you to enjoy the Service we offer in the Transfergest Software, we will use data about you that has been obtained in different ways and at different times. Below you can see in detail:

  • We will use the Personal Data provided when creating a user account;
  • We will use other information held about you to find out how you use the Service provided: your location, your IP address, the trips you make, the identification code assigned internally, your browsing on the Platform (dates and times of access, clicks made, etc.), the hardware, software and browser you use;
  • Finally, we will also obtain information from different social networks, which will be provided to us if you have accepted the respective terms and conditions.

4. What will we use your Personal Data for?

We will use your Personal Data for the following purposes:

  1. Providing the Service

The processing of your Personal Data will be necessary for us to provide our Driver Driven Vehicle Booking Service. Otherwise, you will not be able to enjoy it. The provision of the Service includes the following matters:

– Manage the creation of your user account and allow its use or modification. To use the Service you will need to create an account and identify yourself as a user. You can change the Personal Data provided at any time through the “My Account” section included in the drop-down menu.

– Allow you to make travel bookings.

– Monitor the journeys you make to control the route taken by the driver in real-time. To do this, we need to access your location using the geopositioning systems on your mobile device.

– Contacting you to provide information regarding a journey in progress. These communications can be made by email, telephone or text messages. The form of communication chosen will depend on the reason for the communication.

– Manage your travel payments through the payment method you have pre-established and selected. This functionality allows you to avoid having to include a means of payment each time you book a trip but also implies that we may know your bank information. Nevertheless, please note that we will not use the data on your means of payment for a purpose other than managing your travel payments.

– Allow you to consult the history of all the journeys you have made. – Offer the best service and assistance. Through our Help Centre, we offer assistance at any time to clear up any doubts, comments, suggestions or incidents related to the Service that you may have. This help can only be facilitated if we have your Details on our side.

– Any other matter relating to the provision of the Service.

  1. Marketing actions

We will use your Data to send you news, products and promotions related to Transfergest and third parties related to sectors concerning products and consumption. For this purpose, we will analyse your travel history, the amounts paid, the promotional trips used, how often you use the Service, your sociological profile and your interests. Based on this data, we will create a profile of you so that the promotions sent to you are personalised to suit your personal needs and preferences at all times. Please note that you may at any time ask us to stop analysing your profile, even if this means you will no longer receive news, offers and promotions. The profile we create about you will not be used for any other purpose than to personalise our promotions.

Keep in mind that you may cancel these communications at any time. To do this, simply click on the “unsubscribe” button in any of our communications.

  1. Improving our Service

At Transfergest, we are constantly working on improving the Mobile Application and Website and, for this reason, we carry out tests, research and analytical studies to develop new products that ultimately prove to improve the quality of the Service. This allows us to optimise it, make it more functional and adapt it to your needs (by offering, for example, the option to enter your preferences, your chosen configuration or your frequent locations). Such adaptations often require the use of some of your Personal Data.

  1. Preventing fraud

To prevent potential fraud against you and Transfergest, we have implemented measures to make our Platform a secure place. For example, we will ask you to validate your account. Also, if we detect charges or irregular information, we will contact you to make sure everything is correct. In some cases, it will be necessary to disclose your travel information so that your payment issuers can resolve possible conflicts.

  1. Ask your opinion about Transfergest

It would be very useful to know what you think about Transfergest so that we can make strategic decisions that make us a company aligned with the interests and concerns of our users. For this reason, we may ask you to answer a simple question to find out what your perception of us is.

Keep in mind that we are interested in knowing the opinion of our users to put them on a statistical basis. In other words, after receiving your opinion, we will pseudonymise it, that is, associate it with a code. Subsequently, we will deliver the pseudonymised information to the entity that helps us to carry out these studies so that it can be analysed together with the opinion of other users, to produce a statistical study on the image and perception of Transfergest.

Keep in mind that if you do not want to provide an answer, you do not need to do so.

5. How long will we keep your Personal Data?

The retention period of your Personal Data depends on each of the purposes for which they are used. You can consult them in detail in point 4. In the following table we indicate for how long or until which moment we will keep your data concerning each of the purposes:

  1. Providing the Service

We will use your Personal Data until you decide to leave our Service, i.e. until you delete your user account from our server. As long as you keep your account active, we will continue to process your Data for this purpose. Please note that if there is any unfinished business to resolve concerning the Service, we will endeavour to resolve it before cancellation.

  1. Marketing actions

We will use your Data until you ask us to stop doing so, regardless of whether you continue to use our Service or have unsubscribed. Please note that you can unsubscribe from sending news, offers and personalised promotions at any time by simply clicking on the “unsubscribe” button in any of our communications.

  1. Improving our Service

We will use your Personal Data until you decide to stop using our Service, i.e. until you delete your user account from our server. As long as you keep your account active, we will continue to process your Data for this purpose.

  1. Preventing fraud

As with the previous point, we will use your Personal Data until you decide to stop using our Service, i.e. until you delete your user account from our server. As long as you keep your account active, we will continue to process your Personal Data for this purpose.

  1. Ask your opinion about Transfergest

We will not directly delete your Personal Data; it will be appropriately blocked and protected for as long as liabilities may arise from the Data processing or for such periods as may be required by any applicable law. During such time, your Personal Data will not be processed for any purpose other than to meet such liabilities or to comply with such legal obligations. As a result, only members in a special capacity of Transfergest and members of the IT department may have access to the Data to meet such liability or legal obligations. Once such actions lapse or expire, we will delete your Personal Data promptly and permanently.

6. Why is it lawful for us to use your Personal Data?

At Transfergest, we only use your Personal Data lawfully, as required by applicable law. To do this, we rely on an extensive and reliable legal basis. Below we will indicate the legal basis, i.e. explain why it is lawful for us to use your Data for each of the purposes described in the previous point.

  1. Providing Service

Using your Data will be necessary to be able to execute the contract that binds us to you, from the moment you accept our terms and conditions. Otherwise, you will not be able to enjoy the Services.

  1. Marketing actions

We will use your Data to send you news, offers and promotions based on your profile, but for this to happen, we need your consent. The communications sent may be done by e-mail, SMS or push notifications, whenever you have the Mobile Application open. Please note that you may request at any time not to be sent these personalised communications.

  1. Improving our Service

We consider that at Transfergest we have a legitimate interest to carry out tests, research and analytical studies to improve the quality of our Service, thus allowing us to make it more functional, as you can enjoy a Service that precisely solves your mobility needs.

  1. Preventing fraud

We also understand that we at Transfergest have a legitimate interest to prevent potential fraud in connection with the Service. This treatment is positive for Transfergest and you, as it will allow us to use procedures to prevent fraudulent use of the Service.

  1. Ask your opinion about Transfergest

We believe that we have a legitimate interest in knowing your perception of Transfergest, as it will allow us to make strategic decisions that suit the needs and concerns of all our users. We also understand that the use of your Personal Data for this purpose is compatible with the provision of our Service.

7. Will we share your Personal Data with third parties?

Yes, to provide you with the highest quality of service we need to share your data with the drivers of the vehicles you book and with the entities they work for; with OSB Solutions, Unipessoal Lda, the company that owns all rights to the Transfergest Software; with external suppliers that help us with different issues related to the Service and with third parties.

Entities that help us with different issues related to the Service – making sure that all our suppliers who may have access to your Personal Data do so confidentially, fairly and in full compliance with applicable data protection legislation. To this end, we require them to formalise specific agreements with us governing the use of your Personal Data. Some of our main suppliers are:

  • Storage service provider – this entity helps us store your data and other information related to the Service securely;
  • Public Authorities or Public Bodies for the performance of their functions – sometimes legislation requires data to be provided to public authorities or public bodies for them to perform their functions – such as tax or judicial authorities. Therefore, your Personal Data will be used for this purpose.

8. What are your rights on Data Protection issues?

As a Transfergest user, you have several rights to be able to decide and control, at any time, how we use your Personal Data. These rights may be exercised at any time and free of charge (unless your request is excessive or unfounded, for example, if you have recently exercised the same right with Transfergest; in such a case, we may refuse your request (or charge you), giving you advance notice of a fee. To exercise one of your rights, simply do so via the Help Centre on the Website or the Mobile Application. For us to deal with your request, we need to be sure of your identity, so please provide us with the requested data and tell us which right you wish to exercise. If your request does not meet all the above requirements, please correct it.

In particular, you have the following rights:

  1. Access

You may ask us to indicate whether or not we are using your Personal Data, and if so, we will also tell you additionally what Personal Data we have about you, for what purpose we are using it, with whom we are sharing it, for how long we will retain it, whether we are building personalised profiles, among other issues.

  1. Rectification

You may request that some of your Personal Data be amended so that they are accurate and up to date. All the Personal Data in your user account must always be up to date, so we ask you to bear this in mind.

  1. Elimination

You may request the deletion of Personal Data held by us when it is no longer necessary for the purpose for which it is being used when you withdraw your consent (in case the Data is only processed for purposes based on it).

  1. Limitation

You may request a temporary restriction on the use of your Personal Data when you consider that your data is not accurate until it is verified and/or updated (please note that during this period you will not be able to use the Service); when they are no longer necessary to carry out certain purposes indicated in point 4, but you prefer them to be kept so that you can exercise or defend yourself from claims and finally when you object to the use of your Data for any of the purposes indicated in paragraph 2 of point 4 of this Privacy Policy, while we assess whether the legitimate interest we have in Transfergest prevails over your right to object to their use.

  1. Portability

You may request the direct delivery or delivery to another entity, whenever technically possible, of a structured file, of common use and readable by a computer system, which contains the Personal Data regarding the trips made with the limit indicated in point 4 of this Policy, as well as any other information related to the provision of the Service.

  1. Complaint

Poderá apresentar uma reclamação junto da autoridade de controlo competente em matéria de proteção de dados. Neste caso, as autoridades competentes são as seguintes:

  1. Opposition

You may object to the use of your Data for any of the purposes indicated in paragraph 4.2 of this Privacy Policy. In particular, we remind you that you may request that we no longer analyse your profile in order to send you promotional communications.

9. Will we update this Privacy Policy?

Possibly. Whereas, if for any reason we decide to make any changes to our Privacy Policy, we will let you know in good time before the changes take effect.