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’).
The terms “us", “we" or “our” refer to the Company.
We are committed to protecting our clients’ 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 existing and potential clients.
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
We mainly collect personal data for the purpose of performing our contract with you. We will process the following personal data:
a) Full name, phone number, e-mail and residential address.
b) Geolocation of the passenger, the time and the destination of a journey.
c) Details concerning payment.
d) Information about disputes.
e) Identification data of the device on which MedAsia Cabs App has been installed.
The personal information we collect and hold about you depends on our relationship. The main purpose for our use of your personal data is to connect passengers with drivers to assist them to travel between locations of their choice. In pursuance of this aim, we provide the name, geolocation data and the passenger’s phone number to the drivers that would be delivering a transport service for pick-up purposes. Such data is only collected when the MedAsia Cabs App is activated. Such data may also be used to resolve quality issues or improve quality related to the transport service. We also collect data of the routes taken by drivers with a view to recommending more efficient routes where necessary.
Personal information is moreover, used to communicate with you, make assessments and decisions, assess your eligibility, obtain feedback and manage complaints and queries.
Personal data will be used by us to provide you with marketing information. We will only send you marketing material that you have consented to receiving. Additionally, you have the option of opting out from receiving such marketing material at any stage by sending an email to [email protected] We aim to comply with your opt-out requests within a reasonable time. Please also note that if you do opt-out of receiving marketing communications from us, we may still send you other important service and administration communications relating to the services which we provide to you, and you cannot opt-out from these service and administration communications.
Additionally, details concerning payment are obtained to enable payment process on behalf of drivers in respect of the transport service provided.
We do not sell your personal information, although this information may be shared with other service providers. These third parties have been carefully assessed to ensure that they have appropriate security measures in place to protect the confidentiality and security of personal information.
3. Legal Justification for Processing Personal Data
The GDPR aims to ensure that the way personal data is used is fair.
Personal data is processed in order to provide the service contracted with passengers. We collect and process the personal data submitted by the passengers in the course of installation and use of the MedAsia Cabs App. It is necessary for the use of our services that passengers agree with the processing of identification and geolocation data amongst others.
Personal data may be also processed on legitimate interest grounds, for example but not limited to in investigating and detecting fraudulent payments.
Additionally, we may process your information for marketing purposes and for the provision of our services to you.
4. Personal Data provided to Drivers
The personal data of passengers is only disclosed to drivers who have activated the MedAsia Cabs App. Such personal data will consist of name, phone number and geolocation of passenger and pick up and destination information. This information will remain available to the driver for a reasonable time to enable him or her to resolve any issues concerning the transport service provided.
The quality of the service provided by the drivers is monitored through feedback provided by passengers. Drivers may have access to information concerning passengers providing ratings and feedback on the transport service.
5. 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.
6. Access to your information
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 States 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 issues associated with the use of the services.
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 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 are – [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 [email protected]