Yango Carlash Privacy Notice
Yango Carlash is an electronic service offering to vehicle owners to place an offer to rent a vehicle (Ads), to have access to these Ads and the rental requests to vehicle owners and further agree with the owners on the rent of vehicles (“Yango Carlash” or “Service”).
1. WHAT IS THIS PRIVACY NOTICE FOR?
We are committed to protecting personal data and we want to be transparent about our activities and the way we process your personal data.
The purpose of this Privacy Notice is therefore to inform you how and why we process your personal data.
2. WHO IS PROCESSING YOUR PERSONAL DATA?
Your personal data is processed by RideTechnology Global FZ-LLC, registered at 104A, First floor, Bld. 12, Dubai Internet City, Emirate of Dubai, the UAE (“Yango”).
3. WHAT PERSONAL DATA IS PROCESSED, HOW, AND WHY?
The categories of personal data we process, the source of this data, the purposes and the legal basis of the processing are listed in the table below.
| Source | Categories of Data | Purposes | Legal basis |
| Data provided by users and vehicle owners | Name, phone number, e-mail | To identify and authorise you as our user | Contract* |
| Payment details, bank account number, debit or credit card details, amount payable | To process payments for rent | Contract* | |
| Details of a vehicle | To process and publish vehicle owner’s Ads | Contract* | |
| Received from your device and our apps | IP address, device ID, device type and model, mobile operating system, browser or mobile application details | To secure access to your account and our IT systems | Legitimate interest in ensuring the security of our systems and our users' data |
| Advertising identifier | To customise targeted ads | Consent** | |
| Generated when you interact with our Service or other of our apps | User ID, frequency of visiting, number of screens viewed when interacting with the Service | To improve the app and user experience, to provide relevant features, to modify Service, to prevent unauthorised orders | Our legitimate interest in improving our service and user experience
|
| Daily and monthly income, period of service, driving experience, rating, number of trips | To assess user’s eligibility to rent a vehicle | Contract* | |
| vehicle type, model and brand, VIN, term of the lease, rent amount payable | To process a vehicle rental request, provide a vehicle to a user and charge a rent | Contract* |
| Source | Categories of Data | Purposes | Legal basis |
| Data provided by users and vehicle owners | Name, phone number, e-mail | To identify and authorise you as our user | Contract* |
| Payment details, bank account number, debit or credit card details, amount payable | To process payments for rent | Contract* | |
| Details of a vehicle | To process and publish vehicle owner’s Ads | Contract* | |
| Received from your device and our apps | IP address, device ID, device type and model, mobile operating system, browser or mobile application details | To secure access to your account and our IT systems | Legitimate interest in ensuring the security of our systems and our users' data |
| Advertising identifier | To customise targeted ads | Consent** | |
| Generated when you interact with our Service or other of our apps | User ID, frequency of visiting, number of screens viewed when interacting with the Service | To improve the app and user experience, to provide relevant features, to modify Service, to prevent unauthorised orders | Our legitimate interest in improving our service and user experience
|
| Daily and monthly income, period of service, driving experience, rating, number of trips | To assess user’s eligibility to rent a vehicle | Contract* | |
| vehicle type, model and brand, VIN, term of the lease, rent amount payable | To process a vehicle rental request, provide a vehicle to a user and charge a rent | Contract* |
* The personal data is processed on the basis of a contract defined by the Terms and Conditions of Yango Carlash https://yango.com/legal/yango_carlash_termsandconditions.
** When we request your consent for any type of personal data processing, we inform you of the data collected and the purpose of the data collection. You may refuse to provide such consent and it will not affect your ability to use our apps. You may withdraw your consent at any time by contacting us.
4. WHO DO WE SHARE WITH OR TRANSFER TO YOUR PERSONAL DATA?
4.1 Recipients of Your Personal Data
Your personal data can be shared with third parties:
i) Directly involved in the provision of the services within the app:
- Our partners who are involved in obtaining and handling car rental requests or requests to find a renter your order;
- Payment service providers and mobile money service providers that facilitate electronic transactions;
- Car owners which provided a vehicles for rent;
- Insurance companies;
- Our partners who provide us with electronic payment functionality and carry out anti-money laundering and know-your-customer verifications;
- Our affiliates who provide authentication tools;
- Our affiliates and third parties who provide us with servers, data storage and other infrastructure facilities; and
- Our affiliates and third parties who assist us with customer support.
The entities that may be involved in personal data processing are listed on the following page: https://yango.com/legal/affiliates_yango_group. Not all of the entities listed are necessarily involved in the processing of your data. We do not share personal data between our companies in violation of the applicable privacy law.
ii) Entitled to receive your personal data under the law to which the relevant data controller is subject:
- For example, if law enforcement authorities have a lawful right to have access to your personal data (according to the applicable law in your country and/or the country where our entity providing a service to you is incorporated), or financial regulators are duly entitled to investigate suspicious activities or transactions. We do not share your personal data with state authorities contrary to the applicable privacy law.
iii) Helping us to improve our service:
- For example, data about technical errors encountered while using our services are shared with our affiliates who are involved in the development of our apps.
iv) Helping us to inform you about products, services and offers:
- For example, advertising or device identifiers may be shared with companies that provide us with advertising or analytics services.
4.2 International Transfers of Your Personal Data
Parties we share your personal data with may be located in different countries.
Some of these countries may not provide the same level of data protection or data subject rights as the country where you use a service. In such cases, we follow the necessary procedures to ensure that your rights are respected and that your personal data are protected during and after the transfer.
Such procedures may include (subject to applicable privacy laws):
i) Commitments through data protection agreements based on standard contractual clauses for data transfers issued by relevant authorities;
ii) Additional contractual obligations based on our assessment of the local law of the country where your personal data are transferred and processed;
iii) Registration or authorisation of the transfer from competent data protection authority; and/or
iv) Additional technical and organisational security measures to prevent unlawful, i.e. incompatible with the laws of the country where we provide the service, or unauthorised access to your personal data.
We always comply with the privacy laws of the countries where we operate, including international data transfer requirements and limitations.
4.3 Our Partners acting as data controllers can transfer your personal data to third parties. To learn more about data transfers please contact a Partner which provides you with car rental services.
5. WHAT ARE THE RETENTION PERIODS FOR PERSONAL DATA?
5.1 We process your personal data until the purpose of the processing has been achieved.
5.2 The actual retention period depends on the personal data processed and the country where the processing takes place.
5.3 We may continue to process your personal data, even after you deleted it from the app, if such processing is required by law or is necessary to protect our rights and interests or the rights and interests of third parties, in particular in the context of court proceedings.
The ability to delete data may also be limited by laws relating to freedom of expression and information.
5.4 Where Yango processes personal data as the data processor of the Partner(s) the retention periods are established by the partner.
6. WHAT ARE YOUR RIGHTS?
You have a number of rights under privacy laws. The rights that are available to you depend on the reason we process your personal data and the applicable law.
You can always access, rectify or erase your personal data yourself after logging into the app using our authentication tool.
You may exercise your rights by contacting our customer support team through our apps or via dpo-yt@yango.com.
6.1 Right of Access
You always have access to your personal data. You have the right to request a copy of your personal information.
6.2 Right to Rectification
You have the right to ask us to update or rectify information that you believe is incorrect, inaccurate or outdated. You also have the right to ask us to complete any information that you believe is incomplete.
6.3 Right to Withdraw Consent
You have the right to withdraw your consent to the processing of your personal data where such processing is based on your consent.
6.4 Right to Erasure
You have the right to ask us to erase your personal data in certain circumstances, for example, if the data is no longer needed for our purposes, if we process your data without a valid legal basis or otherwise unlawfully, if you have withdrawn your consent (if the processing was based on your consent), if we collected your data when you were a child, or in other circumstances according to applicable laws.
6.5 Right to Restriction of Processing
You have the right to restrict the processing of your personal data in certain circumstances. For example, if you wish to exercise your right to rectification, you may request that we restrict the processing of your data until it has been rectified.
6.6 Right to Data Portability
If your personal data is processed by automated means based on your consent or based on a contract with us (e.g. to provide you with the features of the app), you have the right to receive your data in a structured, commonly used and machine-readable format.
6.7 Right to Object
You have the right to object to the processing of your personal data if you consider that the processing violates your rights. Please note that the right to object can only be exercised if we are processing your data on the basis of legitimate interests or public interest.
You have the right not to be subjected to a decision based solely on automated processing, including profiling. We do not take decisions based solely on automated processing, including profiling.
6.8 Right to Lodge a Complaint
We are always ready to consider your complaints and suggestions. Please send them to our customer support team.
You may also file a complaint with the appropriate supervisory authority if you believe that your rights have been violated.
7. HOW TO CONTACT US?
7.1 You can contact our customer support team via support@yango.com.
7.2 Our Data Protection Officer can be contacted by email at dpo-yt@yango.com. Please include the phone number you used to register with our app, this will help us to identify you quickly.
8. HOW IS THIS DOCUMENT MODIFIED?
In the event of substantial changes to this Privacy Notice we will publish the new version on our website or we may use any available means (push notifications in the app, SMS, or email) to notify you.
This would be the case, for example, if we add new categories of personal data to be processed or new purposes for which data are processed. You will be notified before such changes take effect.
Date of publication: 07.08.2024.