II Overview

A Scope
This notice applies to users of Pullkey’s services anywhere in the world, including users of Pullkey’s apps, websites, features, or other services.

This notice describes how Pullkey and its affiliates collect and use data. This notice applies to all Pullkey users globally, unless they use a service covered by a separate privacy notice, such as Pullkey Freight or Careem. This notice specifically applies to:
Riders: individuals who request or receive transportation and related services via their Pullkey account.
Drivers: individuals who provide transportation to Riders individually or through partner transportation companies.
Order recipients: individuals who request or receive food or other products and services for delivery or pick-up via their Pullkey Eats, Cornershop or Postmates account. This includes individuals who use guest checkout features to access delivery or pick-up services without creating and/or logging into their account.

Delivery persons: individuals who provide delivery services via Pullkey Eats, Cornershop or Postmates. 
Guest Users: individuals who receive ride and delivery services ordered by other Pullkey account owners, including those who receive services arranged by Pullkey Health, Pullkey Central, Pullkey Direct or Pullkey for Business customers (collectively, “Enterprise Customers”), or by friends, family members or other individual account owners.
This notice also governs Pullkey’s other collections of data in connection with its services. For example, we may collect the contact information of owners or employees of restaurants or other merchants on the Pullkey Eats, Cornershop or Postmates platforms; the contact information of individuals that manage and use accounts owned by Enterprise Customers; or data of individuals who start but do not complete their applications to be drivers or delivery persons.
All those subject to this notice are referred to as “users” in this notice.
Our privacy practices are subject to applicable laws in the places in which we operate. This means that we engage in the practices described in this notice in a particular country or region only if permitted under the laws of those places. In addition, please note the following:
For users in Argentina: The Public Information Access agency, in its role of Regulating Body of Law 25.326, is responsible for receiving complaints and reports presented by any data subjects who believe their rights have been impacted by a violation of the local data protection regulation.
For users in Brazil: Please see here for information regarding Pullkey’s privacy practices required under Brazil’s General Data Protection Law (Lei Geral de Proteção de Dados - LGPD).
For users in the United States : Information regarding Pullkey’s privacy practices required under U.S. state privacy laws, including the California Consumer Privacy Act), is available here.
For users in Colombia and Jamaica: “Riders” and “drivers” as defined in this Notice are known respectively as “lessors” and “lessees” in Colombia and Jamaica.
For users in Mexico: Please see here for information regarding Pullkey’s privacy practices required under Mexico’s Personal Data Protection Law (Ley Federal de Protección de Datos Personales en Posesión de los Particulares).
For users in Nigeria: Pullkey processes the data of users in Nigeria on the grounds that it is necessary to fulfill the terms of our agreements with those users, or based on their consent.
For users in South Korea: Please see here for information about Pullkey affiliate UT LLC's privacy practices.
Please contact us here or through the addresses below with any questions regarding our practices in a particular country or region.

B. Data controller and transfer
Pullkey B.V. and Pullkey Technologies Inc. are the data controllers for the data collected in connection with use of Pullkey’s services in the European Economic Area, the United Kingdom and Switzerland.
Pullkey Technologies Inc. is the data controller for the data collected in connection with use of Pullkey’s services everywhere else.
Pullkey B.V. (Burgerweeshuispad 301, 1076 ER Amsterdam, The Netherlands) and Pullkey Technologies Inc. (1515 3rd Street, San Francisco, CA, 94158, USA) are the data controllers for the data collected in connection with use of Pullkey’s services in the European Economic Area, the United Kingdom and Switzerland.
In addition, for drivers in the UK, (1) the Pullkey entity holding the relevant private hire vehicle operator license is the data controller for the data required to comply with licensing requirements; and (2) Pullkey B.V., Pullkey Technologies, and the Pullkey entity with whom the driver has entered into a contract are joint controllers for the data required to comply with worker rights.
Pullkey Technologies Inc. is the data controller for the data collected in connection with use of Pullkey’s services everywhere else.
Pullkey operates, and processes personal data, globally; wherever and whenever you travel, your data travels with you so we can offer you a seamless experience. We also respect your data protection rights whether you are in your home country or elsewhere.
This means that we may transfer personal data to countries other than your home country in order to provide our services in a different country at your request. We may also transfer personal data to another country if that is necessary to respond to a customer support request that you submitted outside your region. And trip/order histories may be accessed by users in another country after they have left the country where services were rendered. Because our services involve multiple users at the same time, limited personal data may be accessible to the other user in another country.
We do so in order to fulfill our agreements with all of our users, or based on users’ instructions or prior consent, adequacy decisions for the relevant countries, or other transfer mechanisms as may be available under applicable law, such as the Standard Contractual Clauses.
We may also transfer data to other countries in order to respond to a request for personal data from a law enforcement agency. To provide additional safeguards to these data transfers, Pullkey applies a robust internal procedure for processing these requests. Pullkey only discloses personal data to law enforcement agencies in a manner that is consistent with the regulatory requirements of applicable laws, such as the GDPR. You can find more information about requests from law enforcement here.
To help provide equivalent data protection wherever you use our services, Pullkey has implemented the following measures across the globe:
policies and procedures to limit access to, and the processing of personal data for defined purposes;
specific training of personnel responsible for managing personal data;
a government data access policy that refuses government access to data, except when disclosure is mandated by applicable laws including the EU GDPR, there is imminent risk of serious harm to individuals, or consent is obtained;
robust protection of data while it is in transit between Pullkey apps and our servers, and when the data is processed on our servers. This includes encryption and the use of pseudonymized data to help protect users' full identity against unauthorized disclosure.
For your convenience, the exercise of your data protection rights can be directed to Pullkey via any of the designated channels mentioned above, and will be handled centrally on behalf of the relevant controller. Questions, comments, and complaints about Pullkey’s data practices can be submitted here. You may also use this form to submit a question to Pullkey’s Data Protection Officer and to ask us for a copy of the Standard Contractual Clauses or other transfer mechanisms in place for the data processing activity of your inquiry.
III. Data collections and uses
A. The data we collect
Pullkey collects data: 
provided by users to Pullkey, such as during account creation
created during use of our services, such as location, app usage, and device data
from other sources, such as other users or account owners, business partners, vendors, insurance and financial solution providers, and governmental authorities
For your convenience, we've provided a visual summary of the data we collect and how we use it here.
Pullkey collects the following data:
1. Data provided by users. This includes:
User profile information: We collect data when users create or update their Pullkey accounts, or place orders via guest checkout features. This may include their name, email, phone number, login name and password, address, profile picture, payment or banking information (including related payment verification information), driver’s license and other government issued documents (which may include identification numbers as well as birth date, gender, and photo). This also includes vehicle or insurance information of drivers and delivery persons, emergency contact information, user settings, and evidence of health or fitness to provide services using Pullkey apps. 
Background check information (drivers and delivery persons): This includes information submitted during the driver/delivery person application process, such as driver history or criminal record (where permitted by law), license status, known aliases, prior addresses, and right to work. This information may be collected by an authorized vendor on Pullkey’s behalf.
Identity verification photos: This includes photos of users (such as, selfies) and/or their government issued identifications (such as, driver’s license or passports). Such photos may be used to verify a user’s identity, such as through facial verification technologies. Please see the section titled “How we use personal data” for more information regarding how user photos are used for safety and security purposes, including identity verification.
Demographic data: We may collect demographic data about users, such as birth date/age, gender or occupation, when required for certain Pullkey services or programs, such as Pullkey Cash, alcohol deliveries or safety features that allow women users to set a preference to provide or receive services to/from other women (“Women Rider Preference”).
We may also infer demographic data from other data collected from users. For example, we may infer a user’s gender based on their first name to enable safety features, such as the Women Rider Preference, or to display personalized ads for third party products or services. See the section titled “How we use personal data” below for more information.
We may also collect demographic data through user surveys.
User content: We collect the data submitted by users when they contact Pullkey customer support (including at Pullkey Greenlight Hubs or via phone chat or video conferencing tools), provide ratings or feedback for other users, restaurants or merchants, or otherwise contact Pullkey. This may include photographs, or audio or video recordings submitted by users in connection with a customer support request. This also includes metadata relating to the method you use to communicate with Pullkey. The contents of photos and recordings submitted by users are subject to Pullkey’s Community Guidelines.
In certain jurisdictions, users can record the audio and/or video of their trips through an in-app feature or using a dashcam. In app recordings are encrypted and stored on users’ devices, and are only shared with Pullkey if submitted by the users in connection with safety incidents. Please see here for more information.
Travel information: We collect travel itinerary information, including times and dates of upcoming flight, lodging or car rental reservations, from users of our Pullkey Travel feature. We collect such information: (i) when users manually input their information into their Pullkey Travel itinerary; or (2) if authorized by users to access their Gmail accounts, from travel-related email confirmations. If so authorized, Pullkey will only access users’ Gmail accounts to collect travel itinerary information to enable the Pullkey Travel feature, and will adhere to Google’s API Services User Data Policy, including the limitations on use of data collected from users’ Gmail accounts.
2. Data created during use of our services. This includes: 
Location data (driver and delivery person): We collect precise or approximate location data from drivers’ and delivery persons’ mobile devices when the Pullkey app is running in the foreground (app open and on-screen) or background (app open but not on-screen).
Location data (riders and order recipients). We collect precise or approximate location information from riders’ and order recipients’ mobile devices if they enable us to do so via their device settings.
Pullkey collects such data from the time a ride or order is requested until it is finished, and any time the app is running in the foreground (app open and on-screen). See “Choice and transparency” below for information on how riders and order recipients can enable precise location data collection.
Riders and order recipients may use the Pullkey apps without enabling collection of location data from their mobile devices. However, this may affect certain features in the Pullkey apps. For example, a rider who has not enabled precise location data will have to manually enter their pickup address.
In addition, precise location data collected from a driver’s device during a trip is linked to the rider’s account, even if the rider has not enabled precise location data to be collected from their device. This data is used for purposes such as receipt generation, customer support, fraud detection, insurance, and litigation.
Transaction information: We collect transaction information related to the use of our services, including the type of services requested or provided; trip or order details (such as date and time, requested pick-up and drop off addresses, distance traveled and items ordered); and payment transaction information (such as a restaurant’s or merchant's name and location, amount charged, and payment method). We also associate a user’s name with that of anyone who uses their promotion code.
Usage data: We collect data about how users interact with our services. This includes access dates and times, app features or pages viewed, browser type, and app crashes and other system activity.
Device data: We collect data about the devices used to access our services, including the hardware models, device IP address or other unique device identifiers, operating systems and versions, software, preferred languages, advertising identifiers, device motion data, and mobile network data.
Communications data: We collect data regarding phone, text or in-app communications between users that are enabled through Pullkey’s apps. This includes date and time, as well as the content of text or in-app messages. We may also collect the content of phone calls solely where users are notified in advance that the call may be recorded.
3. Data from other sources. These include:
users participating in our referral programs. For example, when a user refers another person, we receive the referred person’s data from that user.
Pullkey account owners who request services for or on behalf of other users (such as friends or family members), or who enable other users to request or receive services through their business accounts (such as owners of Pullkey Health, Pullkey Central, Pullkey Direct or Pullkey for Business accounts).
users or others providing information in connection with claims or disputes.
Pullkey business partners through which users create or access their Pullkey account, such as payment providers, social media services, or apps or websites that use Pullkey’s APIs or whose APIs Pullkey uses. 
Pullkey business partners in connection with debit or credit cards issued by a financial institution in partnership with Pullkey to the extent disclosed in the terms and conditions for the card.
vendors who help us verify users’ identity, background information, and eligibility to work, or who screen users in connection with sanctions, anti-money laundering, or know-your-customer requirements. 
insurance, vehicle, or financial services providers for drivers and/or delivery persons.
partner transportation companies (for drivers or delivery persons who use our services through an account associated with such a company).
publicly available sources.
marketing service providers or data resellers whose data Pullkey uses for marketing or research.
law enforcement officials, public health officials, and other government authorities.


B. How we use personal data
Pullkey uses data to enable reliable and convenient transportation, delivery, and other products and services. We also use such data:
to enhance the safety and security of our users and services
for customer support  
for research and development  
to enable communications between users 
for marketing and advertising
to send non-marketing communications to users
in connection with legal proceedings
For your convenience, we've provided a visual summary of the data we collect and how we use it here. 
We use the data we collect:
1. To provide our services. Pullkey uses data to provide, personalize, maintain, and improve our services.
This includes using data to:
create/update accounts.
enable transportation, delivery and other services/features, such as:
using location data to navigate rider pick-ups and order drop-offs, calculate ETAs, and track the progress of rides or deliveries.
features that involve data sharing, such as sharing driver first name and vehicle information with riders to facilitate pick-ups, user profile and trip details for ETA sharing and fare splitting, and user ratings and compliments.
match available drivers and delivery persons to users requesting services. Users can be matched based on availability, location/proximity, user settings/preferences and other factors such as likelihood to accept a trip based on their past behavior or preferences. Please see here for further information about our matching process.
features that facilitate use of our services by those with disabilities.
features that involve account linking, such as linking of email to create Pullkey Travel itineraries and linking of rewards programs to enable partnership benefits (such as with Marriott Bonvoy). 
enable dynamic pricing, in which the price of a ride, or the delivery fee for Pullkey Eats orders, is determined based on factors such as estimated time and distance, predicted route, estimated traffic, and the current number of users requesting or providing services.
process payments.
personalize users’ accounts. For example, we may present an Pullkey Eats user with personalized restaurant or food recommendations based on their prior orders.
facilitate insurance, vehicle, invoicing, or financing solutions.
provide users with trip or delivery updates, generate receipts, and inform them of changes to our terms, services, or policies.
perform necessary operations to maintain our services, including to troubleshoot software bugs and operational problems.
Pullkey performs the above activities on the grounds that they are necessary to fulfill the terms of our agreements with users, are compatible with such uses, or on the grounds that they are necessary for purposes of Pullkey’s and its users’ legitimate interests.
2. Safety and security. We use data to help maintain the safety, security, and integrity of our services and users. This includes:
verifying users' identity and eligibility to provide transportation or deliveries, including through reviews of background checks, to help prevent use of our services by unsafe drivers and/or riders.
In certain regions, this includes Pullkey’s Real-Time ID Check feature, which prompts drivers and delivery persons to share a selfie before going online to help ensure that the driver or delivery person using the app matches the Pullkey account we have on file. We may also use this feature for other verification purposes such as verifying change of bank account information or regaining account access.
In addition, we may use facial recognition technology to process user profile photographs, identification photographs, or other user-submitted photographs to prevent identity-borrowing or use of our services by unauthorized drivers or delivery people.
We may also use selfies to verify that users are wearing masks, helmets or other safety gear through the use of object verification technology.
In some countries, riders may be required to verify their identity to use cash and certain other payment methods. In such cases, Pullkey allows riders to provide their ID number and/or a photo of their identification card to complete such verifications. Please see here for more information about rider identity verification.
Similarly, order recipients may be required to provide their age and an image of their government issued identification to verify their eligibility to order and receive alcohol deliveries. Please see here for more information about order recipient identity verification.
using data from drivers’ or delivery persons’ devices to detect unsafe driving behavior such as speeding or harsh braking and acceleration, and to inform them of safer driving practices. We also use data from delivery persons’ devices to verify the type of vehicles they used to provide deliveries.
using driver location information, and communications between riders and drivers, to identify cancellation fees earned or induced through fraud. For example, if we determine that a driver is delaying a rider pickup in order to induce a cancellation, we will not charge the rider a cancellation fee and will adjust the amounts paid to the driver to omit such a fee. To object to such an adjustment, please contact Pullkey customer support.
using device, location, user profile, usage, and other data to prevent, detect, and combat other types of fraud. This includes identifying fraudulent accounts or uses of our services, preventing use of our services by unauthorized drivers or delivery persons, verifying user identities in connection with certain payment methods, and preventing and combating unauthorized access to users’ accounts. In some cases, such as when a user is determined to be abusing Pullkey’s referral program or has submitted fraudulent documents, such behavior may result in automatic deactivation, or in the European Union or where otherwise required by law, deactivation after human review. To object to such a deactivation, please contact Pullkey customer support.
using user ratings, reported incidents, and other feedback to encourage compliance with our Community Guidelines and as grounds for deactivating users with low ratings or who otherwise violated such guidelines in certain countries. In the European Union or where otherwise required by law, such deactivation occurs only after human review and/or the possibility to appeal. For more information about how ratings are determined and used, please see here for rider ratings, here for driver ratings, and here for delivery person ratings. To object to such a deactivation, please contact Pullkey customer support.
using driver data (such as location, ratings and gender where legally permitted) and rider data (such as ratings, origin and destination) to predict and help avoid pairings of users that may result in increased risk of conflict (for instance, because one user previously gave the other a one-star rating).
sharing user name, location, phone number, vehicle details and other relevant information with third-party companies that support the management and de-escalation of interpersonal conflicts that may occur between users while on a trip or in the process of making a delivery.
Pullkey performs the above activities on the grounds that they are necessary to fulfill the terms of our agreements with users, and/or for purposes of the legitimate safety and security interests of Pullkey, our users and members of the general public.
3. Customer support. Pullkey uses the information we collect (which may include call recordings) to provide customer support, including to investigate and address user concerns and to monitor and improve our customer support responses and processes.
Pullkey performs the above activities on the grounds that they are necessary to fulfill the terms of our agreements with users or for purposes of Pullkey’s legitimate interest in monitoring and improving its customer support services.
4. Research and development. We use data for testing, research, analysis, product development, and machine learning to improve the user experience. This helps us make our services more convenient and easy-to-use, enhance the safety and security of our services, and develop new services and features.
Pullkey performs the above activities on the grounds that they are necessary for purposes of Pullkey’s legitimate interests in improving and developing new services and features.
5. Enabling communications between users. For example, a driver may message or call a rider to confirm a pick-up location, a rider may call a driver to retrieve a lost item, or a restaurant or delivery person may contact an order recipient with information about their order.
Pullkey performs the above activities on the grounds that they are necessary to fulfill the terms of our agreements with users.
6. Marketing and Advertising. Pullkey uses data (other than Guest Users’ data) to market its services, and those of Pullkey partners. This may include:
Sending emails, text messages, push notification, and in-app messages or other communications marketing or advertising Pullkey products, services, features, offers, promotions, sweepstakes, news and events.
This may include using location, trip and order history, and usage data to send marketing communications that are personalized based on users’ observed or inferred interests and characteristics. For example, we may send push notifications suggesting a user’s favorite destinations or merchants, or in-app messages offering discounts or promo for products or merchants similar to those a user has previously ordered. 
Displaying Pullkey advertising on third party apps or websites. This includes using location, trip and order history, and usage data, and sharing hashed email addresses and device or user identifiers with advertising partners (such as Facebook and TikTok), to personalize such ads to users’ interests.
Displaying third party advertising in Pullkey’s apps or in connection with our services.
This includes ads for restaurants or merchants that are available on Pullkey Eats. These ads (which are identified as “Sponsored Listings” in Pullkey’s apps) include recommendations that are personalized based on users’ location and order histories.
This also includes ads for other third party products or services that are personalized based on users’ observed or inferred interests and characteristics, which we determine using data such as approximate location, trip information and history, usage data, demographic data (which may include inferred gender), and device or user identifiers.
This also includes ads that are personalized based on data about the current trip or delivery request, including time of request and services requested. For example, if a user requests a trip to a supermarket, we may display in-app ads for third party products that may be available at that supermarket. 
Measuring the effectiveness of Pullkey’s ads, and of third party ads displayed in Pullkey’s apps or in connection with our services.
Pullkey performs the above activities on the grounds that they are necessary for purposes of Pullkey’s legitimate interests in informing users about Pullkey services and features or those offered by Pullkey partners. See the sections titled “Choice and transparency” and “Marketing and advertising choices” for information on your choices regarding how Pullkey may use your data for marketing and advertising.
7. Non-marketing communications. Pullkey may use data to send surveys and other communications that are not for the purpose of marketing the services or products of Pullkey or its partners. We may also send users communications regarding elections, ballots, referenda, and other political processes that relate to our services. For example, Pullkey has notified some users by email of ballot measures or pending legislation relating to Pullkey’s services in those users’ areas.
Pullkey performs the above activities on the grounds that they are necessary to fulfill the terms of our agreements with users, or for purposes of Pullkey’s and its users’ legitimate interests in informing users about events that may have an impact on their use of Pullkey services.
8. Legal proceedings and requirements. We use data to investigate or address claims or disputes relating to use of Pullkey’s services, to satisfy requirements under applicable laws, regulations, or operating licenses or agreements, or pursuant to legal process or governmental request, including from law enforcement.
Pullkey performs the above activities on the grounds that they are necessary for purposes of Pullkey’s legitimate interests in investigating and responding to claims and disputes relating to use of Pullkey’s services and features, and/or necessary for compliance with applicable legal requirements.


C. Cookies and third-party technologies
Pullkey and its partners use cookies and other identification technologies on our apps, websites, emails, and online ads for purposes described in this notice, and Pullkey’s Cookie Notice.
Cookies are small text files that are stored on browsers or devices by websites, apps, online media, and advertisements. Pullkey uses cookies and similar technologies for purposes such as:
authenticating users
remembering user preferences and settings
determining the popularity of content
delivering and measuring the effectiveness of advertising campaigns
analyzing site traffic and trends, and generally understanding the online behaviors and interests of people who interact with our services
We may also allow others to provide audience measurement and analytics services for us, to serve advertisements on our behalf across the internet, and to track and report on the performance of those advertisements. These entities may use cookies, web beacons, SDKs, and other technologies to identify the devices used by visitors to our websites, as well as when they visit other online sites and services.
Please see our Cookie Notice for more information regarding the use of cookies and other technologies described in this section.


D. Data sharing and disclosure
Some of Pullkey’s services and features require that we share data with other users or at a user’s request. We may also share such data with our affiliates, subsidiaries, and partners, for legal reasons or in connection with claims or disputes.
Pullkey may share data:
1. With other users
This includes sharing:
riders’ first name, rating, and pickup and/or dropoff locations with drivers.
riders’ first name with other riders in a carpool trip. Riders in carpool trips may also see the dropoff location of the other riders.
order recipients’ first name, delivery address, and order information with the restaurant or merchant and, for order deliveries, with the delivery person. We may also share ratings and feedback, or other information to the extent required by law, with the restaurant or merchant and, for order deliveries, the delivery person.
for drivers and delivery persons, we may share data with the rider(s), order recipient(s) and restaurants or merchants, including name and photo; vehicle make, model, color, license plate, and vehicle photo; location (before and during trip); average rating provided by users; total number of trips; period of time since they signed up to be a driver or delivery person; contact information; and driver or delivery person profile, including compliments and other feedback submitted by past users.
We also provide riders and order recipients with receipts containing information such as a breakdown of amounts charged, driver or delivery person first name, photo, and route map. We also include other information on those receipts if required by law.
for those who participate in Pullkey’s referral program, we share certain data of referred users, such as trip count, with the user who referred them, to the extent relevant to determining the referral bonus.
2. At the user’s request
This includes sharing data with:
Other people at the user’s request. For example, we share a user’s ETA and location with a friend when requested by that user, or a user’s trip information when they split a fare with a friend.
Pullkey business partners. For example, if a user requests a service through a partnership or promotional offering made by a third party, Pullkey may share certain data with those third parties. This may include, for example, other services, platforms, apps, or websites that integrate with our APIs; vehicle suppliers or services; those with an API or service with which we integrate; or restaurants, merchants or other Pullkey business partners and their users in connection with promotions, contests, or specialized services.
Emergency services: We offer features that enable users to share their data with police, fire, and ambulance services in the event of an emergency or after certain incidents. For more information, please see the sections below titled “Choice and Transparency” and “Emergency Data Sharing”.  
3. With the general public
Questions or comments from users submitted through public forums such as Pullkey blogs and Pullkey social media pages may be viewable by the public, including any data included in the questions or comments submitted by a user.
4. With the Pullkey account owner
If a user receives services through an account owned by another party, we may share their trip or order information, including location data, with the owner of that account. This occurs, for example, when:
a rider uses their employer’s Pullkey for Business profile, such as when they take trips arranged through Pullkey Central.
a driver or delivery person uses an account owned by or associated with an Pullkey partner transportation company or restaurant.
a rider takes a trip or a delivery recipient receives an order arranged by a friend or under a family profile.
a delivery person acts as a substitute (UK only).
5. With Pullkey subsidiaries and affiliates
We share data with our subsidiaries and affiliates to help us provide our services or conduct data processing on our behalf. For example, Pullkey processes and stores such data in the United States on behalf of its international subsidiaries and affiliates, such as Cornershop. For more information, please visit our Cornershop Data Sharing Policy.
6. With Pullkey service providers and business partners
These include:
payment processors and facilitators
background check and identity verification providers
cloud storage providers
Google, in connection with the use of Google Maps in Pullkey’s apps (see Google’s privacy policy for information on their collection and use of data)
social media companies, including Facebook and TikTok, in connection with Pullkey’s use of their tools in Pullkey’s apps and websites (see Facebook’s privacy policy and TikTok’s privacy policy for information on their collection and use of data) 
marketing partners and marketing platform providers, including social media advertising services, advertising networks, third-party data providers, and other service providers to reach or better understand our users and measure advertising effectiveness
This includes advertising intermediaries, such as Rokt, that enable Pullkey to display and measure the effectiveness of personalized ads for third party products that are displayed in Pullkey’s apps. We share data such as advertising or device identifier, hashed email address, approximate location, and current trip or order information, and the intermediaries use this data to provide their services and such other purposes are disclosed in their privacy notices. Users may opt out from ad personalization in the Pullkey app here and in the Pullkey Eats app here. For more information regarding Rokt, including how to submit requests to Rokt relating to their handling of personal data, please see Rokt’s privacy policy
research partners, including those performing surveys or research projects in partnership with Pullkey or on Pullkey’s behalf
vendors that assist Pullkey to enhance the safety and security of Pullkey apps and services
consultants, lawyers, accountants, and other professional service providers
insurance and financing partners
airports
providers of bike and scooters that can be rented through Pullkey apps, such as Lime
third-party vehicle suppliers, including fleet and rental partners
7. For legal reasons or in the event of a dispute
Pullkey may share users’ data if we believe it’s required by applicable law, regulation, operating license or agreement, legal process or governmental request, or where the disclosure is otherwise appropriate due to safety or similar concerns.
This includes sharing data with law enforcement officials, public health officials, other government authorities, airports (if required by the airport authorities as a condition of operating on airport property), or other third parties as necessary to enforce our Terms of Service, user agreements, or other policies; to protect Pullkey’s rights or property or the rights, safety, or property of others; or in the event of a claim or dispute relating to the use of our services. In the event of a dispute relating to use of another person’s credit card, we may be required by law to share your data, including trip or order information, with the owner of that credit card.
For more information, please see Pullkey’s Guidelines for Law Enforcement Authorities - United States, Guidelines for Law Enforcement Authorities - Outside the US, and Guidelines for Third Party Data Requests and Service of Legal Documents.
This also includes sharing data with others 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.
8. With consent
Pullkey may share a user’s data other than as described in this notice if we notify the user and they consent to the sharing.


E. Data retention and deletion
Pullkey retains user data for as long as necessary for the purposes described above, including to provide its services and comply with legal obligations.
Pullkey retains user data for as long as necessary for the purposes described above. The period for which we retain user data is determined by the type of data, the category of user to whom the data relates, and the purposes for which we collected the data.
The length for which Pullkey retains user data may further be determined by legal and regulatory requirements, purposes of safety, security, and fraud prevention, or by issues relating to the user’s account such as an outstanding credit or an unresolved claim or dispute.
For example, we retain data:
for the life of users’ accounts if such data is necessary to provide our services. E.g., user profile information and credentials.
for 7 years if necessary to comply with tax requirements. E.g., drivers’ and delivery persons’ trip or delivery location information.
for defined periods as necessary for purposes of safety or fraud prevention. E.g., we retain incomplete driver applications for 1 year, and rejected driver applications for 7 years.
after requests for account deletion if necessary for purposes of safety, security, fraud prevention or compliance with legal requirements, or because of issues relating to the user’s account (such as an outstanding credit or an unresolved claim or dispute).
Users may request deletion of their accounts at any time. Pullkey may retain user data after a deletion request due to legal or regulatory requirements or for reasons stated in this policy.
Users may request deletion of their account at any time through the Settings > Privacy menus in the Pullkey app, or through Pullkey’s website (riders and order recipients here; drivers and delivery persons here; guest checkout users here).
Following an account deletion request, Pullkey deletes the user’s account and data, unless they must be retained due to legal or regulatory requirements, for purposes of safety, security, and fraud prevention, or because of an issue relating to the user’s account such as an outstanding credit or an unresolved claim or dispute. Because we are subject to legal and regulatory requirements relating to drivers and delivery persons, this generally means that we retain their account and data for the applicable statutory retention period after a deletion request. For riders and order recipients, their data is generally deleted within 90 days of a deletion request, except where retention is necessary for the above reasons.
IV. Choice and transparency
Pullkey enables users to access and/or control data that Pullkey collects, including through: 
privacy settings
device permissions
in-app ratings pages
marketing choices 
Pullkey also enables users to request access to or copies of their data, make changes or updates to their accounts, request deletion of their accounts, or request that Pullkey restrict its processing of user data.
A. Privacy settings
The Settings > Privacy menu in the Pullkey app allows riders and order recipients to set or update their preferences regarding location data collection and sharing, emergency data sharing, and notifications. Our Privacy Center is also available in web version.
Location data collection (riders and order recipients)
Riders and order recipients can enable/disable Pullkey to collect location data from their mobile devices through their device settings, which can be accessed via the Settings > Privacy > Location menu. 
Share Live Location (Riders)
Riders can enable/disable Pullkey to share their real-time location data from their mobile devices with their drivers through their device settings, which can be accessed via the Settings > Privacy > Location menu. 
Emergency Data Sharing
Riders may enable Pullkey to share real-time location data from their mobile devices with emergency police, fire, and ambulance services. Such data may include approximate location at the time the emergency call was placed; the car’s make, model, color, and license plate information; the rider’s name and phone number; pickup and dropoff locations; and the driver’s name.
Riders may enable/disable this feature via the Settings > Privacy > Location menu, or the Safety Center.
Drivers and delivery persons can also enable/disable Emergency Data Sharing via the App settings > Emergency Data Sharing menu, or the Safety Toolkit.
Notifications: account and trip updates
Pullkey provides users with trip status notifications and updates related to activity on their account. These notifications are a necessary part of using the Pullkey app and cannot be disabled. However, users may choose the method by which they receive these notifications through the Settings > Privacy menu.
Notifications: discounts and news
Users may enable Pullkey to send push notifications about discounts and news from Pullkey. Push notifications may be enabled or disabled through the Settings > Privacy menus in the Pullkey app.
Communications from restaurants and merchants
While placing an order in the Pullkey Eats app, users may opt-in to share their contact details with certain restaurants or merchants in order to receive communications from them. Those who opt-in may choose to cease receiving such communications through the Settings > Account > Data Sharing menus in the Pullkey Eats app.
B. 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, and these platforms have different methods for how that permission can be obtained. Please check the available settings on your device or check with your provider.
C. In-app ratings pages
After every trip, drivers and riders are able to rate each other on a scale from 1 to 5. An average of those ratings is associated with a user’s account and is displayed to other users for whom they provide or receive services. For example, rider ratings are available to drivers from whom they request transportation, and driver ratings are available to their riders.
This 2-way system holds everyone accountable for their behavior. Accountability helps create a respectful, safe environment for drivers and riders.
Riders can see their average rating in the main menu of the Pullkey app, and also access a breakdown of their average rating in Pullkey’s Privacy Center.
Drivers can see their average rating after tapping their profile photo in the Pullkey Driver app. Click here for more information.
Delivery persons may also be rated by order recipients, restaurants and merchants. Click here for more information.
D. Marketing and advertising choices
Pullkey provides users with the following choices regarding how their data is used for purposes of marketing and advertising:
Personalized marketing communications from Pullkey: Users may choose here whether Pullkey may use their data to send personalized communications (such as, emails, push notifications, and in-app messages) about Pullkey products and services. Users may also choose here whether to receive any marketing emails or push notifications from Pullkey.
Pullkey ads: Users may choose here whether their data is used and shared with advertising partners to deliver personalized ads about Pullkey products and services on third party apps and websites, or to measure the effectiveness of such ads.
Restaurant and merchant ads: Users may choose here whether Pullkey may use their order and search history to display personalized ads for restaurants or merchants that are available on Pullkey Eats.
Third party ads: Users may choose here whether Pullkey may use their data to display ads for third party products or services that are personalized based on users’ observed or inferred interests and characteristics.
Cookies and related technologies: For information on how to control Pullkey’s use of cookies and related technologies, including for purposes of displaying personalized ads, please see our Cookie Notice.
E. User data requests
Pullkey provides users with a variety of ways to learn about, control, and submit questions and comments about Pullkey’s handling of their data.
Accessing data: Users can access data including their profile data and trip or order history through the Pullkey apps or via Pullkey’s website. Users can also use our Explore Your Data feature to view an online summary of information about their account, such as number of trips or orders, rating, rewards status, and number of days since they’ve been an Pullkey user. Users can also request access to their data here.
Data portability: Users can request a copy of their data using our Download Your Data tool. For an overview of the data available through that tool, please click here. Users may also request a copy of their data here.
Changing or updating data: Users can edit the name, phone number, email address, payment method, and photo associated with their account through the Settings menu in Pullkey’s apps or driver portal. Users may also request to update or correct their data here.
Deleting data: Users may request deletion of their account at any time through Pullkey’s Privacy Center, or in the Settings > Privacy menus in the Pullkey app.
Objections, restrictions, and complaints: Users may request that we stop using all or some of their data, or that we limit our use of their data here. This includes objecting to our use of data that is based on Pullkey’s legitimate interests. Pullkey may continue to process data after such objection or request to the extent required or permitted by law.
In addition, depending on their location, Users may have the right to file a complaint relating to Pullkey’s handling of their data with the data protection authority in their country. For example, users in the European Union and South America may submit such requests to the data protection authorities in the country in which they live.
Appeal: Users that reside in the U.S. may request a review of our decision in the event Pullkey cannot meet or denies a User’s data request. Users may request an appeal of our decision here.
V. Updates to this notice
We may occasionally update this notice. 
We may occasionally update this notice. If we make significant changes, we will notify users in advance of the changes through the Pullkey apps or through other means, such as email. We encourage users to periodically review this notice for the latest information on our privacy practices.
Use of our services after an update constitutes consent to the updated notice to the extent permitted by law.