Privacy policy

PRIVACY POLICY
Policy version: ___March 2024
1 INTRODUCTION
This privacy policy (Privacy Policy) is provided by RG Technologies Ltd (trading as PAVE UK), a
company registered in England and Wales under company number: 14925565 with registered office at 4 th Floor, 14 Museum Place, Cardiff, Wales, CF10 3BH, United Kingdom (‘we’, ‘our’ or ‘us’) for the use of our products and services including our mobile app called ‘PAVE UK’ and website situated at www.paveuk.com (collectively referred to as App) developed to provide and enable transportation services and related services, and connect taxi operators/drivers with riders/users (Services).
We take your privacy very seriously. Please read this Privacy Policy carefully as it contains important information on how and why we collect, store, use and share any information relating to you (your personal data). It also explains your rights in relation to your personal data and how to contact us or the relevant regulator in the event you have a complaint. Our collection, storage, use and sharing of your
personal data is regulated by law, including under the UK General Data Protection Regulation (UK GDPR).
We are the controller of personal data obtained via the App in the course of providing Services,
meaning we are the organisation legally responsible for deciding how and for what purposes it is
used.
2 WHAT THIS POLICY APPLIES TO
This Privacy Policy relates to your use of the Services via App only. This notice applies: (a) to the riders (Users) who request to obtain the Services via App; (b) to the taxi operators/drivers (Drivers) who list themselves and their vehicles on the App’s platform in order to provide the Services to the Users of the App; and (c) to any Users of the App who is availing the Services viaApp through other Users’ account or as a guest.
The Services may link to or rely on other apps, websites, APIs or services owned and operated by us or by certain trusted third parties to enable us to provide you with Services such as making or collecting payments, communication services, location services and any other related services to the transportation services. These other apps, websites, APIs or services may also gather information about you in accordance with their own separate privacy policies. For privacy information relating to these other apps, websites or services, please consult their respective privacy policies as appropriate.
3 PERSONAL DATA WE COLLECT ABOUT YOU
The personal data we collect about you depends on the particular activities carried out through the Services via App. RG Technologies may collect and use the following personal data about you as provided by you as a Driver or User of the App:
a. name, profile picture, address(es), government id, email address, date of birth, gender, phone number, user id, password, payment information such as debit card, credit card, bank account details, Stripe payment details, Apple Pay or any such similar payment method when you create or update your account on our App;
b. verification and background check documents such as work authorisations and permit, driver license, passport, driver history (if applicable), vehicle information (such as license plate, color, model, and make), vehicle registration, vehicle insurance, vehicle permit, vehicle photos;
c. ratings, feedbacks, reviews written by Users for Drivers and vice-versa, chat logs between Driver and Users;
d. any saved addresses in the App, travel plans or itinerary as uploaded by the User (including for Chauffeur Services or Airport Cabs);

e. accurate and precise geo-location data of: (a) Users in order to provide pick-up location to the Driver to provide Services to the User, (b) Drivers to allow Users to show the proximity of the Driver in or around the Users requesting for Services, (c) Users and Drivers to ensure the Services are performed correctly.
f. such accurate and precise location data of your device from the time the Service is requested until its fully performed. If usage of location is allowed on your device, it may run in foreground and background during the performance of the Services. If you wish to disable location services on your phone, we do not guarantee that the App may run as it should in normal environment when device location is enabled, and some features maybe disabled. Enabling the accurate device location enhances the performance of the App.
g. Service related data such as pick-up location, drop-off location, time, distance, trip details, order details, distance travelled while providing the Services, payment information, amount charged, type of payment method.
h. device and usage data such as type of device, make, model, IP address, software, device operating system, software, languages, unique and advertising identifiers, device motion data, mobile network, your usage and interaction with our App and Services, timestamps when the App was accessed by you, system activity and any app crash data that you may wish to report to us.
i. any communication data on the App that includes calls and messages between Users and Drivers during the Services;
j. any data from third-party services providers or government authorities who help us do background and verification check; and
k. any such data which User or Driver manually feed into the App via in-app features.
If you do not provide personal data we ask for where it is required, including the geo-location services, it may prevent us from providing services and/or the Services to you.
4 SENSITIVE DATA
Sensitive personal data (also known as special category data) means information related to personal data revealing racial or ethnic origin; political opinions; religious or philosophical beliefs; trade union membership; genetic data; biometric data (where used for identification purposes); data concerning health; data concerning a person’s sex life; and data concerning a person’s sexual orientation.
Please note that we do not knowingly or intentionally collect sensitive personal data or information about criminal convictions from individuals and that you should not submit sensitive data to us.
If, however you do submit sensitive data to us, such as if you make this sensitive data available to other users of the Services we will assume that you have purposefully made any such sensitive data manifestly public.
5 LOCATION SERVICES/DATA
The Services will request your consent to use location services to precisely identify your location each session (i.e. each time the Services is opened or has been placed in the background for more than 30 seconds). We require access to that data in order to provide the Services in the most efficient manner and enhance your experience of using our App for the Services. The location data helps the Driver identifies which User has requested the Service, and pick up details of the User; and helps the User to identify the Driver’s location and proximity for obtaining the Services. If you do not provide your consent, you may use the App but that will mean the location/maps
feature on the App will not be available and the App may not function fully. To withdraw your consent at any time you can turn off the location permissions for our App on your device. The location services in the App will not operate unless location services/data are generally enabled on your device. You may disable such functionality at any time by turning your device’s location on “off” using the device’s settings app. When you allow your device to use location services/data, data will also be collected by Google in accordance with their Privacy Policy, as this is the map service we integrate to our app.

We exert no control over Google’s Privacy Policy and we therefore recommend that you consult their privacy policy for further information on how Google protect personal data please visit their site - https://policies.google.com/privacy?hl=en-US.
6 HOW YOUR PERSONAL DATA IS COLLECTED
We collect personal data from you directly when you sign up to the App through any means suchas

(a) registering or signing up through email id, Facebook login, Instagram login, Google login, orusing any other social media logins, (b) using the App for Services, (c) contacting us directly or reaching out to us via social media, (d) making submissions via the App through chat feature or support line, or (e) indirectly, such as your activities while using the App or Services.
7 HOW AND WHY WE USE YOUR PERSONAL DATA
Under data protection law, we can only use your personal data if we have a proper reason, e.g.:
a. where you have given consent;
b. to comply with our legal and regulatory obligations;
c. for the performance of a contract with you or to take steps at your request before entering into
a contract; or
d. for our legitimate interests or those of a third party.
A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.
RG Technologies uses personal data and any other data that is collected as per this Privacy Policy to provide you with the fully functional App so you can avail the Services which are safe, easy and accessible transportation services. RG Technologies may also use your data provided to us for the following purposes:
a. for providing the access and usage of the App, and to provide safe and secure Services via App;
b. creating, registering and updating accounts on the App to provide Services;
c. enabling transportation services and related services such as using geo-location data to help navigate Drivers to pick-up the Users and provide accurate drop-offs, calculating time, distance and fare for the Services provided by Drivers;
d. connecting nearby Drivers with the Users, and sharing Drivers’ name, phone number, vehicle license plate, color, model, and make, location, photo and other information to the User to facilitate the Services (including to identify the Driver and its vehicle);
e. sharing Users’ name, location, drop off details, phone number to the Driver to provide the Services;
f. enabling generating invoices and receipts, and payment details to the User at the end of each Service, and processing payments through debit cards, credit cards, bank account, Apple Pay, Stripe or such other payment methods as presented on the App to the User;
g. providing Drivers and Users with the trip updates and details throughout the course of the Services;
h. performing operations to maintain the App and Services and to troubleshoot any operational problems or bugs within the App;
i. to make the Users and Drivers feel safe and secure during the provision of Services;
j. verification of the Users’ and Drivers’ accounts and identity, and ensuring Users and Drivers are in compliance of the applicable law;
k. reviewing Drivers’ work authorisation, permit, history, background checks to ensure the safety and security of the Users’ community on the App and Drivers’ eligibility to provide the Services;
l. reviewing and assessing User supplied information on incidents between Drivers and Users for safety incidents, harsh or unsafe driving, obtaining and reviewing device data, location data, make and model of device, vehicle, any other metadata from Users or Drivers to detect and prevent any fraud on the App;

m. reviewing star ratings, feedbacks and reviews by Users and Drivers on the App to promote safety and reliance of the Drivers and Users on the App, and profiles with low score ratings or negative feedback may be deactivated by us;
n. using Driver data to obtain information regarding past trips, incident reports, monthly revenue generated for the Services, and User data to obtain past trip information, amount spent on each trip or cumulative for the Services, pick-up and drop-off locations, saved addresses, reported incidents;
o. to allow communication feature between Users and Drivers via App to enable seamless Services such as sharing of phone number to enable calling, in-app messaging, SMS, Whatsapp;
p. to send Service and Service-related communications to the User and Drivers by RG
Technologies;
q. using the information supplied to us by you, or on the App including chat logs between Drivers and Users;
r. collecting information received by us from you during any support services being provided by RG Technologies to provide support and assist you in investigating the issue that you may have raised in respect of the App or the Services;
s. for sending marketing and advertising communication via emails, SMS or in-app notifications for marketing and advertising Services, and our other products services, promotions, deals, and news;
t. promoting our Services and products on third party apps and websites; or
u. providing any data for legal proceedings including to investigate claims or disputes, to satisfy our legal requirements towards applicable laws and regulations, and for the agreement between you and us, to provide any such data to any government authorities as requested by them. RG Technologies uses your data for the aforementioned reasons as they are necessary to fulfil the Services and perform the terms of our agreement with you, and for legitimate interest of the Users
and Drivers, security interests of RG Technologies and necessary to satisfy the legal compliance and requirements.
8 MARKETING
As stated above, we intend to send you marketing, advertising, promotional emails, SMS, in-app notifications to inform you of our products services such as promotions, news, offers, deals. We will always ask you for your consent before sending you marketing communications, except where you have explicitly opted-in to receiving email marketing from us in the past or except where you were given the option to opt-out of email marketing when you initially signed up for your account with us and you did not do so. You will have the right to opt out of receiving marketing communications at any time by:
a. contacting us at privacy@paveuk.com;
b. using the ‘unsubscribe’ link included in all marketing emails you may receive from us.
We will always treat your personal data with the utmost respect and never sell or share it with other organisations for marketing purposes.
9 WHO WE SHARE YOUR PERSONAL DATA WITH
We routinely share personal data with service providers we use to help us run our business or provide the Services or functionalities in the App, including developers, cloud storage providers and Google, Inc. for Google Maps location functionality. We exert no control over Google’s Privacy Policy and we therefore recommend that you consult their privacy policy for further information on how Google protect personal data - https://policies.google.com/privacy?hl=en-US

We only allow service providers to handle your personal data if we are satisfied they take appropriate measures to protect your personal data. We also impose contractual obligations on service providers to ensure they can only use your personal data to provide services to us and to you.
We or the third parties mentioned above may also need to share your personal data with:
a. external auditors, e.g. in relation to the audit of our accounts and our company —the recipient
of the information will be bound by confidentiality obligations;
b. professional advisors (such as lawyers and other advisors)—the recipient of the information will
be bound by confidentiality obligations;
c. law enforcement agencies, courts or tribunals and regulatory bodies to comply with legal and
regulatory obligations;
d. our payment providers and processors such as banks, ApplePay, Stripe etc., which processes
payment for the Services on our behalf;
e. any third party providers who may conduct background check and verifications on our behalf;
f. research partners who may conduct research and surveys on behalf of us;
g. third party vehicle rental partners; or
h. other parties in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency—usually, information will be anonymised but this may not always be possible, however, the recipient of the information will be bound by confidentiality obligations.
As a User, we will also be sharing your data with the Driver that is assigned to you for providing the Services via App. As a Driver, your data will be shared with the User to provide Services to User as requested by them. This data includes name, contact number, photo, ratings of the User/Driver, pickup and drop off location, vehicle license plate, color, model, and make. We may also share data apart from what is described above if we get consent from you to share such data.
10 HOW LONG YOUR PERSONAL DATA WILL BE KEPT
We will keep your personal data for as long as you have an active account with us and for a period of up to 6 years thereafter to comply with any accounting or legal obligations including in the event of the pursuit or defence of legal claims. Once you have closed your account with us, we will move your personal data to a separate database so that only key stakeholders in our business on a ‘need
to know basis’ have access to such data.
Following the end of the of the aforementioned retention period, we will delete or anonymise your personal data. Otherwise, the Users or Drivers may request deletion of their data in the App through the App’s menu settings or by email us at privacy@paveuk.com.
11 TRANSFERRING YOUR PERSONAL DATA OUT OF THE UK
At this point in time, any data collected under this Privacy Policy by us during the course of providing Services is transferred to and stored in the data centres provided Amazon Web Services
(AWS) Inc., which are situated in the territories of a Member State of the European Union, under the adequacy decision. If we decide to transfer the data outside EEA/UK, we would comply with applicable UK laws designed to ensure the continued protection and privacy of your personal data. Any updated destinations to which we send your personal data, would be indicated in the present section and notified to you in accordance with this Privacy Policy.
Furthermore, under UK data protection laws, we can only transfer your personal data to a country outside the UK where: the UK government has decided the particular country ensures an adequate level of protection of personal data (known as an ‘adequacy regulation’) further to Article 45 of the UK GDPR; there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for you; or a specific exception applies under relevant data protection law.
Accordingly, if we were to start transferring your personal data from the UK to:
a. The EEA: we would rely on the adequacy finding granted by the UK to the EU under the
Withdrawal Agreement to do; for any transfers from the EU to the UK, we would rely on the
adequacy regulation granted to the UK under the Adequacy Decision.

b. Any country located outside the UK/EEA: we would rely an appropriate safeguards under the UK GDPR, such as by including the relevant Standard Contractual Clauses in our data processing agreements In the event we could not or choose not to continue to rely on either of those mechanisms at any time we would not transfer your personal data outside the UK unless we could do so on the basis of an alternative mechanism or exception provided by UK data protection law.
12 YOUR RIGHTS
You generally have the following rights, which you can usually exercise free of charge. For more information regarding these rights, please visit the ICO website here.

For further information on each of those rights, including the circumstances in which they do and do not apply, please contact us (see ‘How to contact us’ below). You may also find it helpful to refer to the guidance from the UK’s Information Commissioner on your rights under the UK GDPR. If you would like to exercise any of those rights, please complete a request form via email, call or write to us, see below: ‘How to contact us’. When contacting us please:
a. provide enough information to identify yourself (e.g., your full name and username) and any additional identity information we may reasonably request from you, and
b. let us know which right(s) you want to exercise and the information to which your request relates.

13 KEEPING YOUR PERSONAL DATA SECURE

We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it. We also have procedures in place to deal with any suspected data security breach. We will notify
you and any applicable regulator of a suspected data security breach where we are legally required to do so. If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.
14 HOW TO COMPLAIN
Please contact us if you have any queries or concerns about our use of your information (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have. You also have the right to lodge a complaint with the Information Commissioner. The Information Commissioner can be contacted at https://ico.org.uk/make-a-complaint or telephone: 0303 123 1113.
15 CHANGES TO THIS PRIVACY POLICY
We may change this Privacy Policy from time to time. When we make significant changes we will take steps to inform you, for example via the App or by other means, such as email. We also request you to kindly review this Privacy Policy from time to time.
16 HOW TO CONTACT US
You can contact us by post, email or telephone if you have any questions about this Privacy Policy or the information we hold about you, to exercise a right under data protection law or to make a complaint. Our contact details are shown below:
Data Protection Officer, RG Technologies Ltd
4 th Floor, 14 Museum Place, Cardiff, Wales, CF10 3BH
Email: privacy@paveuk.com
Phone: 02922712324