This Policy is drawn up comply with the legislation on personal data protection, namely: Regulation (EU) 2016/679 of the European Parliament and of the Council dated 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 “GDPR”) and other applicable regulations on personal data protection.
The controller (operator) of your personal data is VanOnGo Eastern Europe OÜ (registration code 14783810), registered at the address: Harju maakond, Maardu linn, Kallasmaa tn 15-50, 74111, Estonia.
Comply with this Policy, personal data means information about the user defined in Section 2, which is submitted and collected through the VanOnGo App and web page https://vanongo.com/, as well as other web pages that have links to this Policy.
For questions related to your personal data, please contact the Personal data protection Officer (email@example.com).
2. PERSONAL DATA COLLECTION
VanOnGo and the parties acting on its behalf collect the following information:
(i) Data that you voluntary provide when creating an account in the VanOnGo service and updating information in it:
- name, email address, telephone number, username, password, profile photo, payment and banking information (including confirmations), ID state documents data, including the number and a driver’s license photo and date of birth, signature and user’s photo (where applicable, depending on the type of application: “For customers”, “For Carriers”, “For Drivers”). This also includes information about cars and insurance policies of the Users-drivers, as well as user settings. Photos uploaded by User-drivers can be used to verify their identity;
- data of user-Driver about the driving experience, as well as an information about the criminal record (if permitted by law) and the permit to work. This information may be collected by a third party authorized by us on behalf of VanOnGo;
- we may collect demographic data from users, including through surveys;
- we collect information that users send to VanOnGo when they contact support services, rate other Users, leave feedback, create a request for transportation, and so on. This information includes reviews, photos, comments, and User messages;
(ii) Data generated when using the VanOnGo services. These include as follows:
- data on the exact or approximate location of Users, if this is allowed in the settings of their mobile devices. We also link location data collected from User-Drivers’ devices during the trip to User accounts, even if they do not allow such data to be collected from their devices. This is necessary for creating receipts, User support, fraud protection, insurance, and in the event of legal proceedings;
- data about transactions related to the use of our services, including the type of service requested and provided, order and delivery details, date and time of service provision, route length, amount charged, and payment method;
- device data that is used to access our services, including hardware models, IP addresses, operating systems and their versions, software, preferred languages, unique device IDs and serial numbers, advertising identifiers, as well as device movement data and mobile network data;
- data about communications between Users and/or with VanOnGo representatives through our apps and websites. To implement this function, VanOnGo receives data about calls, SMS, and other communications, including their date, time, and content. VanOnGo may use this data for User support purposes (including dispute resolution), security, product and service improvement, and for analytics.
(ii) Data from other sources. These include as follows:
- ratings, reviews, compliments, and other fedback from Users.
- data of Users participating in our attraction programs.
- data of Users and other persons who provide information in the context of appeals and disputes.
- company data that helps us to verify the identity of Users, as well as to verify their documents and their right to work in order to ensure security and compliance with legal requirements.
- data from insurance, transportation, and financial service providers;
- data of partner transport companies (if you are a User-Driver who uses our services through an account associated with such a company).
- data from publicly available sources.
- data from the marketing service providers.
3. PURPOSES OF PROCESSING PERSONAL DATA OF CARRIERS
We collect and process personal data for the following purposes:
- providing the VanOnGo service and enabling Users to enter into transactions among themselves to receive/provide cargo transportation services;
- to analyze the geographical area and provide recommendations to carriers/drivers. If you don’t want to disclose geolocation data for Consignors, you must close the VanOnGo App or indicate in the VanOnGo App that you are not online and are not currently providing transportation services;
- to determine compliance with the legislation and suitability as a carrier/driver based on the driver’s license, profession, identification documents, and information on criminal convictions and offences;
- VanOnGo App displays a photo of the carrier, name and vehicle data to enable the Consignor to identify the carrier/driver and the vehicle, as well as to provide communication between Users;
- in order to detect possible suspicious activities and prevent fraud;
- to monitor compliance with the VanOnGo terms and Conditions, we use information about ratings and User reviews;
- to support the infrastructure for paying for services and processing payments;
- to provide customer support services;
- for marketing messages (in the VanOnGo App, via SMS, push notifications, email);
- to protect the life, health and other vital interests of Users;
- to track and transfer information about the delivery progress;
- to create and send receipts, inform Users about changes in terms, services and rules, and to send other messages not related to advertising services and products of the VanOnGo company and its partners;
- for the study and resolution of claims and disputes associated with the use of the VanOnGo services, and other legitimate purposes, or in response to inquiries from regulatory, state and other official bodies.
4. LEGAL SUBSTANTIATION
We collect and use personal data only when we have a legitimate ground to do so. The need to collect and process personal data of various contents is justified by the relevant GDPR regulations.
Personal data is processed for the execution of a public contract between VanOnGo and Users, as well as transactions for receiving/providing transportation services between Users.
Personal data may be processed in case if there is a legally justified interest in investigating and detecting suspicious payments.
Personal data is processed to protect the legitimate interests of VanOnGo or third parties. Data on criminal records and offenses are processed for the purpose of compliance with the law.
In addition, we may share information about criminal activities or threats to public safety with law enforcement agencies, including through legal proceedings at the request of third parties.
Some personal data is collected and used with your consent. In particular, we collect personal data through voluntary surveys. The responses received from such surveys are used with your consent and are deleted as soon as the survey goals are achieved.
A user who has given his/her/its consent for collecting and processing of personal data can revoke it at any time, but in this case he/she/it will lose access to the services and functions that require such data to be provided.
5. TRANSFER AND DISCLOSURE OF PERSONAL DATA
Some of VanOnGo’s products, services, and features involve transmitting information to other Users or providing them with data upon request. In addition, we may share personal data with our subsidiaries and business partners if there are legal grounds for doing so or if it is necessary to satisfy claims and resolve disputes.
You can only disclose some of your personal data from the VanOnGo App to Users whose order was sent/accepted.
Upon your request, we may disclose your data to other Users. In addition, with your consent, we may share information with third parties in situations not covered by this Policy, if we have notified you of our intention to disclose the information and you have given your consent to do so.
Depending on the User’s location, personal data may be disclosed to local VanOnGo subsidiaries, their representatives, affiliates, agents, etc. The personal data processing is subject to the terms of this Policy.
In cases provided for by law and upon request, we may transfer your personal data to the competent state authorities.
6. DATA STORAGE AND DESTRUCTION
VanOnGo stores profile data, transaction information, and other personal data as long as the User’s account remains active.
After receiving a request to delete your account, VanOnGo may continue to store certain information if required or permitted by law.
VanOnGo Users can send a request to delete their account at any time. Upon receiving such a request, VanOnGo will delete all the information except for the one that is required to store in accordance with legal, tax, insurance, judicial and other legal requirements. For example, VanOnGo stores payment information, location, device, and platform usage data for a maximum of 5 years. VanOnGo may use the stored information for security purposes, fraud detection and prevention, as well as for researches and development.
VanOnGo may also store certain information if necessary to block a User’s account for violating security rules, in order to prevent such User from creating a new account in the VanOnGo Service in the future.
7. RIGHTS OF USERS WITH RESPECT TO THEIR PERSONAL DATA
You have the following rights in connection with your personal data processing:
(i) the right to receive information about what data we process about you and a copy of the personal data processed;
(ii) the right to correct an inaccurate information;
(iii) the right to delete or erase your data. This right is not absolute and does not apply if law requires data processing;
(iv) the right to request that we restrict the processing of your data. In this case, we may still store your data, but we will not use it in the future;
(v) the right to transfer data, i.e. the right to request your personal data transfer from us to another company;
(vi) the right to object to certain processing of your personal data, including processing for direct marketing;
(vii) the right to withdraw your consent, however, the revision will not affect the lawfulness of processing based on your consent obtained before the revocation;
(viii) the right to file a complaint with the data protection Supervisory authority if you believe that our processing of your personal data does not comply with the applicable data protection law. The Supervisory authority is the Estonian Data Protection Inspectorate (www.aki.ee);
(ix) some of the above rights apply only in certain cases. If you would like to exercise any of your rights, please contact us by email firstname.lastname@example.org.
8. PROCESSING OF CONSIGNORS ‘ PERSONAL DATA
You do not have the right to process other Users’ personal data without our permission or the User’s expressed consent. You have no right to contact any User or collect, register, store, access, use or cross-use personal data provided by the User or available to you through the VanOnGo Service for any reason other than for purposes of providing/receiving delivery services.
You must comply with the terms and conditions for processing Users’ personal data. In case if you violate requirements for personal data processing, we have the right to block your account and demand covering damages from you.
We may make changes to this Policy from time to time. Our services utilization after the Policy has been updated indicates your acceptance of such changes to the extent permitted by law.
In case if changes are significant, we will notify you in advance via the VanOnGo App or by other means, such as e-mail. We recommend that you view this page from time to time to stay up to date with the latest changes.
10. DISPUTES RESOLUTION