Privacy notice

The data controller is Kenjy Saadi, trading under the name UrbanGo, with its place of business at Via Pasquale Lucchini 10, 6900 Lugano, Switzerland.

For any request about your personal data you can write to [email protected].

The controller is established in Switzerland, so the Federal Act on Data Protection applies. And because the service is offered to people in the European Union as well, Regulation (EU) 2016/679 (GDPR) applies too, and the UK GDPR to those in the United Kingdom. Where one of them gives you more, the one that gives you more is the one that counts.

This notice should be read together with the Terms and conditions, which explain how the service works.

This notice concerns:

• Passengers, that is whoever requests or takes a journey;
• Drivers, that is whoever carries out the journey using their own UrbanGo profile;
• Operator staff, that is the people who use the platform to handle requests;
• Partner contacts, that is whoever books journeys at a hotel or a company that has an arrangement with an operator;
• Event agencies and their contacts, that is whoever publishes a booking request for an event;
• Anyone who leaves their details in a form on the site, even before having a profile.

Account data. First name, surname, email address, telephone number, a profile picture if there is one, and sign-in credentials in encrypted form.

Driver data. Vehicle and registration, licences and authorisations as declared, the fares that have been set, currency and prepaid credit balance.

Operator staff data. Name, email, telephone and the role assigned by the operator, together with a record of the actions carried out on the platform.

Booking data. Pick-up and destination address with their coordinates, distance, times, number of passengers, notes entered by whoever took the request, amounts and outcome.

Location. A driver’s location is collected only while they are on duty, so that nearby bookings can be offered to them and their operator can see where they are. It stops being collected when they go off duty. The location of a passenger using the app is collected in order to fill in the pick-up point.

Payments. Credit top-ups are handled by the Stripe platform. We do not see and do not keep your card details: we keep the transaction reference Stripe returns and, if you choose to save a payment method for later top-ups, the reference by which Stripe identifies it.

Technical data. Access and usage logs and, if you allow notifications, the device identifier needed to send them.

Cookies: we do not use any. The site sets no profiling, analytics or third-party cookies. The only thing stored on your device is the language you chose, kept by the browser so that you find it again when you come back. That is why there is no consent banner: there is nothing to consent to.

We keep the data of the bookings. It is not information that disappears at the end of the journey: it is the operator’s history, the basis on which commission is calculated and, where the law requires it, the content of the journey record.

The history is visible to the operator that handled the booking and to the driver who carried it out, each for the part that concerns them.

We do not record how much the driver actually took from the passenger: that money does not pass through us and is not ours to know.

To perform the contract. Creating and managing the profile, bringing request and driver together, calculating fares and commission, managing prepaid credit.

To let the transport operators find you, where your organisation registers for that purpose. It is not an optional extra on top of the service: it is the service. An agency that publishes a request and no operator that reads it is not a reduced version of UrbanGo, it is an empty page. Clauses 7 to 11 say what we disclose, and to whom, for each category.

To meet legal obligations. Accounting, tax requirements and, where it is required, producing and keeping the journey record.

For our legitimate interests. Keeping the platform secure, preventing abuse, support and improving the service.

With the operator that handles the booking and with the driver who accepted it, limited to what it takes to carry it out.

The passenger’s telephone number is made available to the driver only after acceptance, and for as long as it takes to carry out the journey, so that they can ring you if they cannot find the address. A driver who refuses a booking does not get your number.

With third-party providers that process data on our behalf, and which we name one by one so that you know where it goes:

• DigitalOcean, which hosts the service and the database. The servers are in Frankfurt, Germany, so inside the European Union;
• Stripe, which handles credit top-ups. We do not see and do not keep your card details;
• Google, for address search and route calculation: it receives the address you search for and the coordinates that come from it;
• Telegram, which receives an internal alert when somebody fills in a form on the site. The alert contains what you wrote in the form, name and email included, and exists so that we can answer you the same day.

We host the site statistics ourselves, with Umami, on our own servers: they do not go to any outside provider. It is also why you will not find a cookie banner, because we set no cookies.

With the taxi and private hire operators in the areas you have indicated, where your organisation registers so that they can find it: an event agency, a hotel, a company. We tell them that your organisation has registered, and we show them the booking requests you publish, in whole or in part, so that they can offer you a service. It is the reason you register: without it the operators would not know you exist and you would have nobody to ask.

We share the organisation’s details and those of the request, not your personal data beyond what it takes to be recognised. You choose the areas when you register, and outside those we disclose nothing.

It lasts as long as the registration does and ends when the profile is closed.

On closure we stop disclosing anything new. What has already been sent stays with whoever received it, because a request an operator has already read cannot be called back.

We do not sell personal data and we do not pass it to third parties so that they can advertise to you. What is described above is a different thing: it happens only at your request, towards those who can give you the service you are looking for, and it stops when you say so.

What we collect. Of whoever registers: name, email address and telephone. Of the agency: registered name, trading name, VAT number, address and contact details, the areas you usually work in, the kind of events you run and how many of them you run in a year.

Why. So that the transport operators in the areas you have indicated can find you. It is the purpose of registering, not an addition to it: an advertisement no operator reads is of no use to anybody.

Who with. With the taxi and private hire operators in the areas indicated, and with nobody else. We tell them your organisation has registered and we show them the requests you publish, in whole or in part.

Of the contact we disclose only what it takes to be recognised. The rest of their personal data stays out of it: an operator needs to know which agency it is talking to, not who filled in the form.

For how long. For as long as the registration lasts. It ends when the profile is closed.

What we collect. Of the contact: name, email address and telephone. Of the organisation: name, address and contact details. Plus the journeys you book on behalf of your guests or customers.

Why. To route your requests to the operator they are meant for.

Who with. With the operator the request is meant for, and with the driver who carries it out, limited to what it takes to carry it out.

Your guest’s data. When you enter a booking for somebody else, that person’s name and telephone number follow the rules in clause 11, including the one by which their number reaches the driver only after acceptance.

What we collect. Of the operator: name, address, contact details, licences and authorisations as declared, the fares and booking fees that have been set. Of the staff who use it: name, email, telephone and the role assigned by the operator.

We record what each member of staff does on the platform. Who took a request, who assigned it, who cancelled it. It is what makes the operator’s history possible, and that history is also the basis on which commission is calculated.

That record stays even once the person has left. The archive has to be able to go on saying who did something, months after that person changed jobs. When their profile is closed the identifying data is removed; the trace of the action is not.

Who with. With the affiliated drivers, for the bookings they accept. With the partners you have arrangements with, for the requests they send you. One operator’s bookings are not visible to another.

What we collect. Name, contact details, vehicle and registration, licences and authorisations as declared, the fares you have set, currency and prepaid credit balance.

Your location is collected only while you are on duty, to offer you nearby bookings and to show your operator where you are. When you go off duty it stops being collected.

The passenger’s telephone number reaches you only after you have accepted, and for as long as it takes to carry out the journey, so that you can ring them if you cannot find the address. If you refuse a booking, you do not get that number.

Who with. With the operator you are affiliated to, for the bookings it handles. You may be affiliated to more than one operator: each sees its own bookings.

We do not record how much you actually took from the passenger: that money does not pass through us.

What we collect. Name and telephone number, pick-up and destination address with their coordinates, time, number of passengers and any notes.

Your location is used to fill in the pick-up point when you use the app, and you are the one who provides it.

Your telephone number reaches the driver only after they have accepted the booking, and for as long as it takes to carry it out. Drivers who refuse do not get it.

Who with. With the operator that handles the booking and with the driver who carries it out. If the booking was made for you by a hotel or a company, also with whoever made it, limited to that booking.

The service and the database are in Europe, on servers in Frankfurt. We are established in Switzerland, so for us the European Union is abroad too: Switzerland, however, recognises the States of the Union as offering an adequate level of protection, and for those in the Union the data does not leave at all.

Two providers process data outside Switzerland and the Union as well, and we say which:

• Google, for address search and route calculation;
• Telegram, for the internal alert that reaches us when you fill in a form.

In both cases the transfer is made on the basis of the standard contractual clauses approved by the European Commission and recognised by the Swiss Federal Data Protection and Information Commissioner, which are the instrument provided for when the destination country has no adequacy decision.

Stripe processes payment data under its own contractual safeguards, on the same basis.

We keep data for as long as it takes to provide the service and, for accounting data, for the period the law imposes.

Closing a profile removes the personal data but not the accounting records. On closure, the identifying data held in the profile is removed; the records of bookings, commission and top-ups remain, stripped of identifying data and to the extent needed to reconstruct economic dealings that have already been concluded.

Any remaining prepaid credit ends with the profile, as provided in the Terms.

You can at any time ask:

• to see your personal data and to receive a copy of it;
• to have it corrected or completed;
• to have it erased, within the limits of our retention obligations;
• to restrict or object to the processing;
• to withdraw a consent already given;
• to receive it in a machine-readable format.

Where the processing is what makes the service work, the limit is closing the profile. Objecting to a processing operation without which the service does not exist would not reduce it, it would empty it: for disclosure to the operators, clause 6 applies.

Requests should be sent to [email protected].

You also have the right to go to a supervisory authority: in Switzerland the Federal Data Protection and Information Commissioner, which is the authority of the place where we are. If you are in the United Kingdom you can go to the Information Commissioner’s Office; if you are in the European Union, to the authority of your own country, for instance the Garante per la protezione dei dati personali in Italy or the CNIL in France.

We may update this notice, for instance when the law changes or when we introduce a new service. The date at the top shows when it was last updated.