Privacy policy

1. Introduction
1.1 We are committed to safeguarding the privacy of all users of PhoneTaxi OP App ("PhoneTaxi OP").
1.2 This policy applies where we are acting as a data controller with respect to the personal data of such persons; in other words, where we determine the purposes and means of the processing of that personal data.
1.3 In this policy, "we", "us" and "our" refer to the developer "Aitrago Limited". For more information about us, see Section 10.
2. Credit
2.1 This document was created using a template from Docular (https://seqlegal.com/free-legal-documents/privacy-policy).
3. The personal data that we collect
3.1 In this Section 3 we have set out the general categories of personal data that we process and, in the case of personal data that we did not obtain directly from you, information about the source and specific categories of that data.
3.2 We may process data to enable us to contact you with your location ("location data"). The purpose of processing location data is to accurately allocate orders after confirming your location. Location data may include your mobile phone‘s International Mobile Device Identification Number (IMEI), location information, software installation list and MAC address.
3.3 We may process data enabling us to get in touch with you ("contact data"). The contact data may include your name, email address, telephone number, postal address and/or social media account identifiers. If you log into our website using a social media account, we will obtain elements of the contact data from the relevant social media account provider.
3.4 We may process your PhoneTaxi OP user account data ("account data"). The account data may include your account identifier, name, email address, business name, account creation and modification dates, personal settings and marketing preferences. The primary source of the account data is you, although some elements of the account data may be generated by PhoneTaxi OP. If you log into our website using a social media account, we will obtain elements of the account data from the relevant social media account provider.
3.5 We may process information relating to transactions, including purchases of goods and/or services, that you enter into with us and/or through PhoneTaxi OP ("transaction data"). The transaction data may include your name, your contact details, your payment card details (or other payment details) and the transaction details. The source of the transaction data is you and/or our payment services provider.
3.6 We may process information contained in or relating to any communication that you send to us or that we send to you ("communication data"). The communication data may include the communication content and metadata associated with the communication.
3.7 We may process data about your use of PhoneTaxi OP and services ("usage data"). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system.
3.8 We may use third-party applications and software development kits (SDK) including but not limited to AutoNavi Map; AutoNavi; AutoNavi positioning; Ali Auto Map (com.amap.api) to obtain your geographic location for use in the above 3.2 purpose. We use uni-app for development which intergrates com.xiaomi.push, com.getui, com.g.gysdk, com.xiaomi.mipush, com.igexin.sdk, com.huawei.agconnect to provide push notification function.
4. Purposes of processing and legal bases
4.1 In this Section 4, we have set out the purposes for which we may process personal data and the legal bases of the processing.
4.2 Operations - We may process your personal data for the purposes of operating PhoneTaxi OP, the processing and fulfilment of orders, providing our services, supplying our goods, generating invoices, bills and other payment-related documentation, and credit control. The legal basis for this processing is our legitimate interests, namely the proper administration of PhoneTaxi OP, services and business.
4.3 Publications - We may process account data for the purposes of publishing such data on PhoneTaxi OP and elsewhere through our services in accordance with your express instructions. The legal basis for this processing is our legitimate interests, namely the publication of content in the ordinary course of our operations.
4.4 Relationships and communications - We may process contact data, account data, transaction data and/or communication data for the purposes of managing our relationships, communicating with you (excluding communicating for the purposes of direct marketing) by email, SMS, post, fax and/or telephone, providing support services and complaint handling. The legal basis for this processing is our legitimate interests, namely communications with PhoneTaxi OP visitors, service users, individual customers and customer personnel, the maintenance of relationships, and the proper administration of PhoneTaxi OP, services and business.
4.5 Direct marketing - We may process contact data, account data and/or transaction data for the purposes of creating, targeting and sending direct marketing communications by email, SMS, post and/or fax and making contact by telephone for marketing-related purposes. The legal basis for this processing is our legitimate interests, namely promoting our business and communicating marketing messages and offers to PhoneTaxi OP visitors and service users.
4.6 Research and analysis - We may process usage data and/or transaction data for the purposes of researching and analysing the use of PhoneTaxi OP and services, as well as researching and analysing other interactions with our business. The legal basis for this processing is our legitimate interests, namely monitoring, supporting, improving and securing PhoneTaxi OP, services and business generally.
4.7 Record keeping - We may process your personal data for the purposes of creating and maintaining our databases, back-up copies of our databases and our business records generally. The legal basis for this processing is our legitimate interests, namely ensuring that we have access to all the information we need to properly and efficiently run our business in accordance with this policy.
4.8 Security - We may process your personal data for the purposes of security and the prevention of fraud and other criminal activity. The legal basis of this processing is our legitimate interests, namely the protection of PhoneTaxi OP, services and business, and the protection of others.
4.9 Insurance and risk management - We may process your personal data where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks and/or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
4.10 Legal claims - We may process your personal data where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
4.11 Legal compliance and vital interests - We may also process your personal data where such processing is necessary for compliance with a legal obligation to which we are subject or in order to protect your vital interests or the vital interests of another natural person.
5. Providing your personal data to others
5.1 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice.
5.2 Your personal data held in PhoneTaxi OP database will be stored on the servers of our hosting services provider Alibabacloud in Hong Kong.
5.3 Financial transactions relating to PhoneTaxi OP and services are handled by our payment services providers, Asiapay Hong Kong. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. You can find information about the payment services providers' privacy policies and practices at www.asiapay.com.
5.4 In addition to the specific disclosures of personal data set out in this Section 5, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise, or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
6. International transfers of your personal data
6.1 In this Section 6, we provide information about the circumstances in which your personal data may be transferred to a third country under UK and/or EU data protection law.
6.2 The hosting facilities for PhoneTaxi OP are situated in Hong Kong. The competent data protection authorities have made an adequacy determination with respect to the data protection laws in Hong Kong.
6.3 You acknowledge that personal data that you submit for publication through PhoneTaxi OP or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.
7. Retaining and deleting personal data
7.1 This Section 7 sets out our data retention policies and procedures, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
7.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes. We retain your personal data as long as needed to provide services or products to you, or as required or permitted by applicable laws, such as tax laws.
7.3 We will only retain your personal data within the time required to achieve the purpose of the privacy policy, unless an extension of the retention period is needed or if it is legally permitted.
7.4 Notwithstanding the other provisions of this Section 7, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
8. Your rights
8.1 In this Section 8, we have listed the rights that you have under data protection law.
8.2 Your principal rights under data protection law are:
(a) the right to access - you can ask for copies of your personal data;
(b) the right to rectification - you can ask us to rectify inaccurate personal data and to complete incomplete personal data;
(c) the right to erasure - you can ask us to erase your personal data;
(d) the right to restrict processing - you can ask us to restrict the processing of your personal data;
(e) the right to object to processing - you can object to the processing of your personal data;
(f) the right to data portability - you can ask that we transfer your personal data to another organisation or to you;
(g) the right to complain to a supervisory authority - you can complain about our processing of your personal data; and
(h) the right to withdraw consent - to the extent that the legal basis of our processing of your personal data is consent, you can withdraw that consent.
8.3 You may exercise any of your rights in relation to your personal data by written notice to us, using the contact details set out below.
9. Amendments
9.1 We may update this policy from time to time by publishing a new version on PhoneTaxi OP.
9.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
10. Our details
10.1 PhoneTaxi OP is developed by Aitrago Limited whose address is at Unit B&C, 20/F., Full Win Commercial Centre, 573 Nathan Road, Kowloon, Hong Kong.
10.2 You can contact us:
(a) by post, to the postal address given above; or
(b) by email, using the email address published on PhoneTaxi OP.
11. Data protection officer
11.1 Our data protection officer's contact detail: eric.tang@aitrago.com.