Sea Pebbles Catering Ltd., a private limited liability company, registered in Malta (Company Registration Number C80952), whose office is situated at 90, The Strands, Sliema (the ‘Company’), is the controller of personal data of passengers and has appointed a Data Protection Officer who can be contacted at [email protected] (‘DPO’).
We are committed to protecting your privacy and we will not collect any personal information about you unless you provide it voluntarily. This policy describes and explains how information is collected and retained by us. This information helps us improve our service to you.
The GDPR seeks to protect and increase the rights of data subjects. These rights cover the safeguarding of personal data, protection against the unlawful processing of personal data and the unrestricted movement of personal data within the EU. The GDPR does not apply to information already in the public domain.
1. Personal data
In general, the personal information we gather about you enables us to process your Transport Services and to provide MedAsia Cabs Services to you. When you download the MedAsia Cabs App, we collect your device type, your wireless carrier, and your individual device ID and we associate this with your personal information. That said, we primarily use this information to support your Account and provide you with MedAsia Cabs Services.
When you register with us to use the MedAsia Cabs Services, you will be asked to complete application forms and online forms and for the purpose of performing our contract with you, we will process the following personal data:
a) Full name, e-mail address, phone number, VAT number, place of residence and image photo for your profile.
b) Geolocation information of drivers and driving routes.
c) Type and specification of vehicle and vehicle registration plates
d) Driver’s efficiency and performance ratings.
e) Driver’s licence, profession and identity documents.
f) Data about criminal convictions and offences.
2. Purpose, Legal Justification for Processing Personal Data and Recipient of Data
The purpose for which we collect and process personal data is for you to be able to use and enjoy our MedAsia Cabs Services namely to connect Passengers with Drivers to assist them to move around more efficiently.
Geolocation and driving routes are processed with a view to analysing the geographical area and give suggestions to the Drivers. When you close our MedAsia Cabs App or indicate that you are offline and not providing Transport Services, the geolocation will not be disclosed to Passengers.
We require to collect and process your driving licence, identity documents and criminal convictions and offences to ensure suitability of you to act as a professional Driver.
We will make available the Driver’s photo to Passengers as well as full name and vehicle details to enable Passengers to identify the Driver and his vehicle. Moreover, this way we personalize your Transport Service to the Passenger that has the right to choose the Driver. Passengers also see Driver’s personal data in the receipt.
In addition, tracking information is collected as you use our MedAsia Cabs Services, including, but not limited to geographic areas. Through your mobile phone and/or any other portable device we will record your GPS coordinates. We collect this information in order to provide you with the history of your routes and do not use it for any other purpose.
We also collect device type and unique identifier when you use our MedAsia Cabs App. We use this information for the sole purpose of providing you with the most up to date application and features. If you use our services through your mobile device and/or any other portable device, we will track your geo-location information so that you are able to be located. We may also collect your geo-location even when you are not using MedAsia Cabs App, only in case you have given us your consent, in order to provide you with further efficient geo-based-services. We will not share this information with third parties for any purpose and will only use this information for the sole purpose of finding a cab and providing further services. You may at any time no longer allow our application to use your location by turning this off at the device level.
Driver’s efficiency and performance ratings will be collected and processed as necessary to provide a reliable service to Passengers. You will be given a summary of your efficiency and performance ratings.
Personal data may moreover be collected and processed on the ground of legitimate interest to enable investigations where necessary and in case of fraud.
We use your personal data to closely monitor which features of our MedAsia Cabs Service are used most, to allow you to view your trip history, view any promotions we may currently be running, rate trips, and to determine which features we need to focus on improving and to send SMSs or notifications for confirming that the Driver has or remind that he or she has arrived or is about to arrive at the designated destination. We use the mobile and/or portable device information collected so that we are able to serve you the correct App version depending on your device type, for troubleshooting and in some cases marketing purposes.
We may also use your personal information to create anonymous information records by excluding information that makes the information personally identifiable to you.
We will send you strictly service-related announcements on rare occasions when it is necessary to do so. Generally, you may not opt-out of these communications, which are not promotional in nature. If you do not wish to receive them, you have the option to deactivate your Account. On the other hand, you can always opt out of receiving certain communications from us such as our newsletter by clicking the “Unsubscribe” link at the bottom of each email or emailing us at [email protected] Please note that even if you unsubscribe or opt-out, we may still send you Transport Service booking related communications.
3. Security and access
The personal data we collect is securely stored within our database, and we use standard, industry-wide, commercially reasonable security practices such as encryption and firewalls for protecting your information.
However, we cannot guarantee the security of our database, nor can we guarantee that information you supply won’t be intercepted while being transmitted to us over the Internet, and any information you transmit to the Company you do at your own risk. We recommend that you not disclose your password to anyone.
4. Sharing of your Personal Data with Passengers
For a Passenger to make use of your Transport Service, we must share with him or her your geo-location information. If you are available, you will appear at the Passenger’s search – your full name, VAT number, image photo for your profile, type and specification of vehicle, vehicle registration plates and evaluation will be displayed to the Passenger. We will also display your phone number after the Passenger selects you and you accept. While we encourage Passengers to comply with our data protection requirements, we will not be responsible if they fail to comply with respect to your information. At the end of your journey, if you are evaluated by the Passenger that you have provided Transport Service, this information will be made available to anyone that uses the MedAsia Cabs App, as part of your evaluation.
5. Sharing of your Personal Data to Third Parties
Additionally to the above, we may share your Personal Data with other third parties such as services providers under contract who help us in our business operations. We require such service providers to use your information only in connection with the services that they perform for us. We may also share your Personal Data as required to comply with a legal obligation. We will require your consent to share your Personal Data to any other third parties.
You may not process the Personal Data of Passengers without our permission. You are moreover not allowed to contact any Passenger or collect his or her Personal Data or use any Personal Data that had been disclosed to you in relation to the Transport Service for any reason other than for the purpose of the provision of such Transport Service.
7. Cookies and other anonymous information
8. Your rights
In terms of the GDPR you have a number of rights in connection with your personal information. The following is a description of the data protection rights available to individuals in the EEA:
Right of access to personal information – you have the right to receive a copy of the information that we hold about you.
Right of rectification of personal information – you can update your personal data via the MedAsia Cabs App.
Right to erasure of personal information – in certain circumstances you can ask for the data we hold about you to be erased from our records.
Right to restriction of processing of personal information – you have the right to request that we suspend our use of your personal information in certain circumstances;
Right to data portability – you can obtain your personal information in a format which enables you to transfer that personal information to another organization. However, this right only applies in certain circumstances.
Right to object to processing of personal information – You have the right to object to our use of your personal information in certain circumstances.
Right to object to automated processing, including profiling – you also have the right not to be subject to the legal effects of automated processing or profiling in certain circumstances.
Right to complain to the relevant data protection authority – should you think that we have processed your personal information in a manner that is not in accordance with data protection law, you can make a complaint to the Office of the Information and Data Protection Commissioner.
If you wish to exercise these rights, please contact us using the details below.
You may request us at any time what information is effectively held on you if any, at that particular time. All requests should be made to [email protected] or writing to us at the address further below.
Any personal data collected in the course of providing the services is transferred to and stored in the data centers of Hetzner Online GmbH and/or Amazon Web Services, Inc. and/or Google Commerce Limited, which are located in the territories of a Member State of the European Union.
Only authorised employees of the Company have access to the personal data and they may access the data only for the purpose of resolving issues associated with the use of the services.
Geolocation data is processed in anonymised form and personalized only if the geographical location data is needed to be linked to a passenger for resolving disputes or fraud.
For research and scientific purposes, the data is used in unidentified form (anonymized).
Your personal data will be stored as long as you have an active passenger account. If your account is closed, personal data will be deleted (according to the policies set out in this section) from the databases, unless such data is required to be retained for accounting, dispute resolution or fraud prevention purposes.
The following data will be stored for the following periods, namely –
Personal Data Retention Period
Financial data regarding transportation services provided to passengers 3 years after the last journey
Data required in case of suspicions of a criminal offence, fraud or provision of false information 10 years
Data required for accounting purposes 10 years after the last journey
Data relating to disputes concerning payment until the claim is satisfied or the expiry date of such claims
History of journey 3 years, after which data may be anonymized
If you de-install the MedAsia Cabs App from your device, your personal data will still not be deleted. However, if you fail to use the MedAsia Cabs App for a period of six (6) months we will ask you if you still want to retain an active Account. If no reply is received, we reserve the right to close your Account whereupon your personal data will be deleted unless required to be retained as afore-stated. In this respect, you are to note that a request to delete your personal data may only be entertained if we delete your Account. Any request for deletion of personal data in terms hereof will be entertained within one month (subject to the above retention periods).
If you wish to raise a complaint about how your personal data has been processed by us, you have the right to complain to the Company’s DPO.
The details for this contact is – [email protected]
The supervisory authority is the Office of the Information and Data Protection Commissioner which can be contacted at Level 2, Airways House, High Street, Sliema SLM 1549, Malta or by telephone on (+356) 2328 7100 or by email at idpc[email protected]