Hala Privacy Policy

This Privacy Notice explains how RTA Careem LLC (collectively “Hala”, “we” or “us”) collects and uses Personal Data.

This Privacy Notice applies to all users of Hala’s ride-hailing services in relation to Hala taxis (including special taxis such as Hala Vans or Hala Juniors), and when ride-hailing users interact or communicate with us in relation to Hala’s services (all collectively, the “Services”).

Hala offers its Services on an intermediation platform made available by Careem Deliveries FZ LLC (the “Careem Technologies” or “Careem Platform”). In order for you to access the Services, you will need to download the Careem App and register an account. The terms of use and privacy notices relating to the Careem Platform can be found at https://www.careem.com/en-AE/privacy-policy

Unless stated otherwise, Hala is the data controller for the Personal Data collected in connection with the use of Hala’s Services. Where a User’s first booking is for a Hala Taxi, or if you use any of these car types which are fitted with a digital screen that you choose to interact with, then Hala is a controller of the Hala Trip Data. Hala has engaged Careem Networks FZ LLC (“Careem Rides”), directly and through its sub-processors, subcontractors and licensors (collectively, the “Careem Rides Group”), to provide certain technology and Processing services to Hala in support of Hala’s business within the UAE. The data controller of all personal data collected on the Careem Platform is Careem Technologies. As a result, Careem Rides has engaged Careem Technologies and/or GPC Computer Software Limited (“Autocab”) as sub-processors to process your Personal Data on Hala’s behalf and to enable you to access or use the products or services provided by Hala. To the extent that you are using Hala services, then any Personal Data that you provide through the Careem Platform will be Processed by Careem Rides, Careem Technologies, Autocab and Hala for the purposes of Hala providing its service to you. When using Hala’s services, you are also agreeing to this Processing of Personal Data by Careem Networks, Autocab, and/or Careem Technologies on behalf of Hala for these purposes, and to the transfer of any Personal Data about you that Careem Rides Processes for these purposes to Hala. When this occurs, Hala is responsible for determining the purpose and means of that Processing. To the fullest extent permitted under Applicable Laws, Careem Rides shall have no liability under or in connection with the processing of Personal Data in connection with Careem Rides’ provision of services to Hala.

Our privacy practices also apply to Captains, Suppliers, Guest Users and Visitors.

1. DEFINITIONS

Please take note of the following key definitions that will be used throughout this Privacy Notice:

Applicable Law means any law that applies to our processing of your Personal Data, whether by virtue of offering Services to you, monitoring your behaviour online (such as by using Cookies), your use of our Services or the provision of your services to us.

Controller means the party that determines the purpose and means of processing personal data.

Hala Trip Data is any Personal Data that is received when you use Hala’s ride-hailing services in relation to Hala taxis.

Personal Data is any data or information that relates to an individual and which could, of itself or in combination with other data or information, identify who an individual is.

Processor means the party that carries out the processing of personal data.

Process or Processing means the collection, storage, use or transfer of Personal Data.

2. SCOPE AND APPLICATION

This Privacy Notice applies to all individuals anywhere in the world who access or use our Services. It specifically applies to:

Users: individuals who book or request to book transportation services via a Hala taxi, including individuals who receive transportation requested by another individual.
Captains: individuals who are authorised by the Roads and Transport Authority of the Emirate of Dubai to provide (or apply to provide) transportation of people through taxi franchise companies authorised to work with Hala.

3. LEGAL BASIS FOR THE PROCESSING OF PERSONAL DATA
We rely on the following legal basis for processing your data:

Contractual Necessity: This basis applies when we must use your data in order to provide the services you request
and meet our responsibilities under the contract to which you are a party to. For example, to provide and maintain
our Services and to send administrative or Service-related messages.
Consent: This legal basis applies when we notify you how we will collect and use your data and you voluntarily agree
to that use of your data. Where we rely on consent, you have the right to withdraw your consent at any time, in
which case we will cease that collection and use of your data. For example, to send personalized marketing
communications.
Legitimate Interest: This legal basis applies when Hala or a third party to whom personal data has been disclosed
processes your data for legitimate purposes (such as for purposes of safety, security, and fraud detection and
prevention), provided this processing of data is necessary for those purposes and the benefits of those purposes are
not in conflict with your fundamental rights and freedoms. For example, we process personal data to analyze and
enhance the performance of our Services, based on our legitimate interest in improving service quality and ensuring
the platform operates efficiently for all.
Legal Obligation: This legal basis applies when we are required to comply with a mandatory legal requirement or
order issued by a competent court. For example, to screen Captains before enabling certain services.

4. COLLECTION OF INFORMATION

Depending on the Services you are accessing or using, we collect and use the following data:

information that you provide directly to us;
information about the use of your account and our Services; and
information obtained from other sources and third parties, which may include information about you.

PART A: Information You Provide to Us

Hala collects Personal Data that you provide directly to us through your access or use of the Services. You are solely responsible for the accuracy of the information you provide, and Hala will only modify or update your Personal Data upon your request or when you modify your account details.

We collect Personal Data that you provide directly to us through your access and use of the Services, such as when you:

create or modify your account on the Careem Platform for the use of any of our Services;
access Hala via the Careem Platform;
request Services on your behalf or on behalf of others;
contact Hala’s customer support;
complete User surveys or provide feedback; or
otherwise communicate with us.

The Personal Data collected may include your:

name;
email address;
place of employment i.e. if you use an enterprise/corporate email address;
phone number;
addresses that you store in your profile for future reference;
payment method;
residential address;
payment information, including your preferred payment method, on condition that Hala uses a third-party PCI-compliant vendor to
process and store credit and debit card information; and
other information which we reasonably require or that you choose to provide.

Personal Data of children under 18 years of age
Hala does not knowingly collect, keep or maintain Personal Data from children below 18 years old. If you book a ride or use another of our Services on behalf of a child under the age of 18 then we might indirectly collect information about that child. Each time you are booking a ride or using another of our Services on behalf of a child under the age of 18, you represent and warrant to us that:

you have the legal right to do so on behalf of the child;
you have the legal right to provide consent on the child’s behalf to the collection and use of that child’s Personal Data by us; and
you provide that consent to us by continuing to book the ride or using our Services on behalf of the child to the fullest extent possible under Applicable Laws.

Please note that if you choose not to provide us with some of this Personal Data, or request that we erase some or all of it, we may not be able to provide you with our Services at all or provide it to the same standard we can if we are using that Personal Data.

Captains

If you are a Captain working with Hala, we may also collect Personal Data when you:

request to create or modify your account for use of any of our Services as a Captain; and
attend a Hala or third-party premises to onboard as a Captain;

The Personal Data collected may include your:

name;
email address;
phone number;
postal address;
date of birth;
gender;
residency card (copy) and the information included on it;
driving licence (copy) and the information included on it;
reference letter;
payment information, including your preferred payment method and bank account details, on condition that Hala uses a third-party PCI-compliant vendor to process and store credit and debit card information;
proof of non-conviction record (if required under Applicable Laws);
evidence of health or fitness to provide services (if required under Applicable Laws); and
other information which we reasonably require or that you choose to provide.

PART B: Information We Collect Through use of Our Services

When you access or use our Services, either as a User or Captain, we collect information, some of which will constitute Personal Data. In some cases, we collect this data through cookies, pixels, tags, and similar tracking technologies that create and maintain unique identifiers. Such information may include your:

mobile network information;
mobile operating system;
mobile application crash reports;
mobile application features and applications used;
time zone setting;
device location;
IP address;
device information, including the type of mobile device you use, a unique device identifier (for example, your device’s IMEI number, the MAC address of the device’s wireless network interface, installed applications, or the mobile phone number used by the device);
SMS data;
transaction-related information;
information on safety-related incidents;
browsing history information (i.e. any third-party services you accessed or used before using our Services); and
registration history information.

If you are a User, we may also collect:

details of the specific Service you have requested;
Captain feedback you choose to provide;
your specific location at the time you are accessing or using our Services;
GPS location;
the time and date of your booking of the Service;
your booked or actual destination;
your trip route; and
the Personal Data of individuals on whose behalf you access or use our Services, for example, when you book a ride for others.

Captains: If you are a Captain, we also collect:

any User feedback you choose to provide;
your trip route; and
the time and date of any bookings you accepted, rejected or cancelled.

PART C: Information We Collect From Other Sources

We may also receive information, including Personal Data, from other sources and combine that either with Personal Data we receive from you or collect through our Services. For example:

if you engage with a separate app, website or service that uses an API, we may receive information about you or your connections from that site, app or service;
if your employer uses one of our enterprise solutions, we may receive information about you from your employer;
we may receive information from your employer (or similar entity) if your employer (or similar entity) participates in any of our enterprise/corporate solutions; and
we may obtain Personal Data from third parties who help us verify an individual’s identity and background information for legal, regulatory, anti-money laundering, safety, and security purposes. This can include screening against sanctions lists, lists of politically exposed persons and relatives/close associates of such persons, and adverse media.

If you are a User we may also:

collect information about you from your employer, if your employer uses one of our enterprise solutions; and
receive ratings by Captains after they have provided services to you.

Captains: If you are a Captain we may also:

receive ratings by Users after you have provided services to them;
collect information through your employer (a partner transportation company that we contract with), the regulator of any such partner transportation company or one of its suppliers; and
collect information if you also interact with the Services in another capacity, for instance as a Captain, we may combine or associate that information with Personal Data which has been collected from you in your capacity as a User or passenger.

5. USE OF PERSONAL DATA

We may use Personal Data collected in the manner described above to:

provide, maintain, and improve our Services
perform internal administration and operations, including conducting data analysis, testing, and research; monitoring and analyzing usage and activity trends; and troubleshooting software bugs and operational problems
send or facilitate communications i.e., between Users and Captains;
send communications to you, including administrative or service-related messages, receipts and other communications we think will be of interest to you, including information about existing and/or new products, services, promotions, news, and events of Hala and other companies, where permissible and according to Applicable Laws;
process contest, promotion entries and fulfil any related awards;
allow you to participate in interactive features of our Services;
keep our Services safe and secure, including screening Captains and Users before enabling their use of our Services and at subsequent intervals, including through reviews of background checks, where permitted by law, to help prevent use of our Services by unsafe Captains and/or Users;
prevent, detect, and combat fraud or unsafe activities, including by using device, location, profile, usage, and other data;
personalise and improve the Services, including to provide or recommend features, content, social connections, referrals, and advertisements;
using User and Captain ratings and feedback to encourage compliance with Hala’s terms and as grounds for deactivating Captains with low ratings or who otherwise violate such guidelines; and
to ask you about your experience using our Services, including about a particular Captain.

6. SHARING OF PERSONAL DATA

Depending upon the purposes for which we have collected your Personal Data, we may share your Personal Data:

Users and Captains:
We may share your Personal Data:

with third parties that we use to carry out work on our behalf or to perform a contract we enter with them, including:
○ Careem Rides Group in the manner described in this Privacy Notice;
○ Careem Technologies in relation to making available the Careem Platform for booking and completion of Hala trips and acting as a sub-processor on behalf of the Careem Rides Group;
○ Google, in connection with the use of Google Maps/Earth in Careem Platform (see Google’s privacy policy and Google Maps/Google Earth Additional Terms of Services for information on their collection and use of data at https://www.google.com/policies/privacy and https://maps.google.com/help/terms_maps.html, respectively).
○ social media companies, including Facebook, in connection with Hala’s use of their tools (see Facebook’s Privacy Notice for information on their collection and use of data);
○ vendors who help us verify identity, background information, or who screen users in connection with sanctions, anti-money laundering, fraud or know-your-customer requirements. In some cases, these service providers may retain identity documents that are suspected to be fraudulent for the purpose of identifying fraud in the future.
○ cloud storage providers;
○ payment processors and facilitators;
○ marketing partners and marketing platform providers, including social media advertising services, advertising networks, third-party data providers, and other service providers that help us understand you better as a user and measure advertising effectiveness;
○ research partners, including those performing surveys or research projects in partnership with Hala or on Hala’s behalf;
○ vendors that assist Hala to enhance the safety and security of our Services; and
○ consultants, lawyers, accountants, and other professional service providers;
○ airports, including when required by airport authorities as a condition of operating on airport property;
○ financial institutions, such as banks we partner with to offer joint products.

with third parties, including Careem Technologies, to market their products or services if you have agreed to receive promotional updates;
if we otherwise notify you and you consent to the sharing;
with third parties in an aggregated and/or anonymised form which cannot reasonably be used to identify you;
with law enforcement officials, financial regulators, anti-money laundering agencies, government authorities, public health officials, competent authorities or other third parties: (i) to enforce or apply our Terms of Use; (ii) to investigate potential breaches of these terms or applicable laws or if we believe your actions are inconsistent with our Terms of Use; (iii) to protect the rights, property, or safety of Hala or others; or (iv) if we believe disclosure is in accordance with, or is otherwise required by any applicable law, regulation, operating license or agreement, legal process or governmental requests, or where the disclosure is otherwise appropriate due to safety or similar concern;
with a claims processor or an insurer to provide any necessary information (including your contact information) if there is a complaint, dispute or conflict, which may include an accident, involving you and another party and such information or data is necessary to resolve the complaint, dispute or conflict; and
with third parties in connection with, or during negotiations of, any merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or into another company.

Users Only:
We may share your Personal Data:

with Captains, to enable them to provide the Services you request. For example, we share your name and pickup and/or drop-off locations with Captains;
With third parties with whom you choose to let us share your Personal Data, including other applications or websites that integrate
with our API or Services, or those with an API or service with which we integrate;
with Careem Rides Group in the manner identified in this Privacy Notice; or
with your employer (or similar entity) if your employer participates in any of our enterprise/corporate solutions.

Captains Only:

We may also share your personal data with:

Users, to enable them to identify you and your vehicle; and
your employer.

7. AUTOMATED DECISION TAKING
We use personal data to make automated decisions relating to use of our Services, such as to:

determine Captains and Users ratings, and deactivate where there are low ratings;
match available Captains to Users requesting services based on availability, proximity, and other factors;
enable dynamic pricing, in which the price of a ride or the delivery fee is determined based on constantly varying factors such as the estimated time and distance, the predicted route, estimated traffic, and the number of Captains and Users using Hala at a given moment; and
flag Captains and/or Users who are identified as having engaged in fraud, unsafe activity, or other activities that may harm Hala and/or others.
Hala performs the above activities because they are necessary to fulfil our obligations to users under our Terms of Use or other agreements with users, or because they are necessary for purposes of the legitimate interests of Hala, its users and others.

8. INTERNATIONAL TRANSFER OF PERSONAL DATA
Reflecting the regional span of our business, we process personal data globally. This means we may also transfer personal data to countries other than the one where you live or use Hala’s Services. When we transfer your Personal Data abroad, we will take appropriate measures to protect your Personal Data in accordance with this Privacy Notice and the laws of the country from where the transfer is occurring.

Where Applicable Laws require you to consent to the processing of personal data outside the country where you access the Careem Platform, you provide that consent to us by continuing to book the ride or using our Services to the fullest extent possible under the Applicable Laws.

9. STORAGE OF PERSONAL DATA
We will store and retain your Personal Data for the period of time necessary for the purpose for which the data has been collected, unless the nature of the purpose changes in which case the retention period may be extended or shortened.

Apart from the purposes for which we collect your Personal Data, we also store and retain this Personal Data to preserve the integrity of our databases, to carry out ongoing Services on your behalf, for research, analytics and statistics purposes and to ensure compliance with applicable laws and regulations.

Following an account and/or data deletion request (where warranted in accordance with the data subject rights referred to below), we will erase or archive from active use the Personal Data of the individual to which the requirement or request relates, unless we are required to retain it due to legal or regulatory requirements, for purposes of safety, security, and fraud prevention, or because of an issue relating to your account such as an outstanding credit or an unresolved claim or dispute.

10. YOUR CHOICES

Device permissions
Most mobile device platforms (iOS, Android, etc.) have defined certain types of device data that apps cannot access without the device owner’s permission. Different platforms have different methods for how that permission can be obtained. Please check the available settings on your device or check with your provider.

Marketing and Opting Out
You consent that both Hala and Careem Rides may use the Personal Data you provide to Hala for either Careem Rides or Hala directly contacting you to market their separate services to you.

Hala provides Users with the opportunity to opt out of receiving direct marketing communications from us:

in any direct email marketing communication that you receive from us; and
for Users, from the ‘Settings’ menu in the Careem Platform mobile application.

Data Subject Rights
Depending on the country you are in at the time that we collect and use your Personal Data and the Services that you use, you may have some or all of the following rights under applicable law:

The right to access.
You may request access to your data, including your profile data and trip or order history (commonly known as a “data subject access request”). If the information you request reveals personal data about a third party, we will: (i) seek that individual’s consent before responding to your request, (ii) consider if it is otherwise reasonable to provide it to you; or (iii) we will redact any third-party personal data before responding. If we are unable to provide you with access to your personal data because disclosure would infringe the rights and freedoms of third parties, we will notify you of this decision.

To request erasure of your Personal Data. This enables you to ask Hala to erase Personal Data where:
your Personal Data is no longer needed for the purposes for which it was collected;
the sole legal ground for processing was your consent and you have withdrawn it;
you have objected to the processing of your Personal Data on the legal grounds relating to your particular situation, and Hala cannot prove that there are overriding legitimate interests for processing;
your Personal Data was processed unlawfully; or
your Personal Data must be erased in order to comply with legal requirements.

Please note that requests to delete your account will also be subject to the terms and conditions of the Careem Platform. If you have an enterprise/corporate account, we may be unable to process your deletion request if there are outstanding payments for that enterprise account.

Hala may be required to retain some data in line with legal or regulatory requirements, for purposes of safety, security, and fraud prevention, or because of an issue relating to your account such as an outstanding credit or an unresolved claim or a dispute.

To object to us processing of your Personal Data where Hala is relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground.
To request us to restrict our processing of your Personal Data where:
you consider that our processing of your Personal Data is inaccurate;
you consider that the processing is unlawful, and you oppose the erasure of your Personal Data and you require the restriction of the processing instead;
we no longer need the Personal Data for the purposes of the processing, but the Personal Data is required by you for the establishment, exercise or defence of a legal claim; or
where you require verification that processing on the legitimate interests of Hala overrides your interests.
To revoke your consent, where we have expressly asked for your consent as a legal basis to process your Personal Data. The revocation of your consent will not affect the lawfulness of the processing based on your prior consent.

Depending on your location, you may be able to exercise these rights through the Settings menu in the Careem Platform mobile application or by contacting us at legal@halaride.com.

You may be contacted for additional information if we are unable to verify your identity, the scope of your request is unclear or does not provide sufficient information for us. Once we have all the information, we need to locate your personal data, we will begin processing your request.

Applicable law may allow or require us to refuse to act on your request, or we may have destroyed, erased, or made your personal data anonymous in accordance with our record retention obligations and practices. If we determine that your request does not have a legal basis, we reserve the right not to further process your request and we will inform you of this decision.

In addition, depending on your location, you may have the right to file a complaint relating to our handling of your Personal Data with the data protection authority in your country.

11. SECURITY PRECAUTIONS

Your Hala profile, created through the Careem Platform, is password-protected so that only you and authorised Hala, Careem Rides Group and their employees or service providers (“Authorised Personnel”) have access to your account information. Hala’s Authorised Personnel will never proactively reach out to you and ask for any personal account information, including your password.

Hala makes every effort to ensure that your Personal Data is secure on its systems. Hala has staff dedicated to maintaining adherence to this Privacy Notice and other privacy initiatives, periodically reviewing the security of the Services and making sure that all Hala staff are aware of our security practices. Unfortunately, no data transmission over the Internet can be guaranteed to be 100% secure. As a result, Hala cannot guarantee the security of any Personal Data you transmit to us, and you do so at your own risk.

To the extent permitted by Applicable Law, Hala expressly disclaims any liability, and you hereby waive any claims, and indemnify us for any claims that may be brought by third parties who access or use our Services via your account, that may arise should any other individuals obtain the Personal Data Hala collects about you or third parties who access or use our Services via your account.

12. COOKIES

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our website and the Hala Services. By accessing and browsing our website, you are agreeing to our use of cookies.

13. GUEST USERS

We consider you a Guest User if you receive trips but are not the owner of an account on the Careem Platform, such as when a Hala trip is arranged for you by another account owner.

Guest User personal data may be associated with, and accessible by, the owner of the Careem Platform account.

In these cases, your personal data is used and may be shared with third parties:

to provide trips; and
for purposes of safety and security, customer support, research and development, enabling communication between users, and in connection with legal proceedings and requirements.

14. SUPPLIERS

We consider you a Supplier if you are an individual (other than a Captain) who provides services to Hala, either in your own capacity, or on behalf of an organisation as a member or employee of that organisation.

If you are a Supplier or work for a Supplier, we collect Personal Data when you, or the business that you represent, provide, or seek to provide us with, services; or otherwise communicate with us.

The Personal Data collected may include:

your name;
your email address;
your phone number;
your postal address;
passport or national identification number;
bank information where payment for Services will be made;
information on shareholders, principal officers, financial history, references, and ultimate beneficial owners; and
other information which we reasonably require or that you choose to provide.

We may use Personal Data collected in the manner described above to:

contact you with regard to the provision of your services to us;
facilitate payments to you; and
consider our potential or current relationship with your business.

If you are a Supplier, we will be relying on third parties who help us verify identity and background information for legal, regulatory, anti-money laundering, sanctions and security purposes. This can include screening against sanctions lists, lists of politically exposed persons and relatives/close associates of such persons, and adverse media.

Please note that if you choose not to provide us with some of this Personal Data, or request that we erase some or all of it, we may not be able to engage you or continue to engage you to provide services to us.

15. VISITORS

We consider you a Visitor if you visit Hala’s premises other than as a Hala employee or individual contractor. When visiting Hala’s premises, you may be asked to input personal information and/or register as a visitor.

This information is used to ensure the safety of individuals within Hala premises and to safeguard information that is shared with you during your visit at Hala premises.

16. CHANGES TO THIS PRIVACY NOTICE

We may change this Privacy Notice from time to time. If we make significant changes to the way we treat your Personal Data, or to this Privacy Notice, we will provide you notice through the Services or by some other means, such as email or a push notification.

To the extent permitted by Applicable Law, your continued use of the Services after such notice constitutes your consent to the changes to the extent permitted by law.

We encourage you to periodically review this Privacy Notice for the latest information on our privacy practices.

17. CONTACT US

If you have any questions, comments and requests related to this Privacy Notice, or if you have any questions about how Hala processes your Personal Data, please contact us at legal@halaride.com.