Privacy Policy

INFORMATION REGARDING THE DATA CONTROLLER For individuals in Ireland, the data controller as per Art. 4 No. 7 GDPR is: Free Now Ireland Limited. (“FREE NOW”) 7-12 Baggot Court, Dublin 2, D02 F891, Ireland The data controller has appointed a data protection ofﬁcer (DPO). The easiest way to reach our data protection ofﬁcer is by sending a message via https://support.free- now.com/hc/en-ie/requests/new or by writing to the foregoing address with the subject: “The Data Protection Ofﬁcer.”
DEFINITIONS “Personal Data“ is all information which relates to an identiﬁed or identiﬁable natural person. Among these are, for example, name, postal address, e-mail address or telephone number, but also usage data like your IP address. “Processing“ is every process carried out with or without automated assistance or every sequence of such processes in connection with personal data, e.g. obtaining, capturing, organizing, ordering, saving, adjusting or modifying, sorting, ac-cessing, using, disclosing by transmission, distributing or any other form of making available, comparing or connecting, limiting, deleting or destroying. “Taxi Providers” (also “Providers”) are Platform users who publish and offer services. Providers offer taxi rental, related activities and other services (together the “Services”) as a “Listing” on the platform “Taxi Renters” (also “Renters”) are Platform users who search for, seek to book or use services. “Platform” is the FREE NOW Taxi Marketplace platform which facilitates engagement between Providers and Renters for the purposes of taxi rental. All commercial and legal arrangements are entered into outside of the Platform. As the provider of the Platform, FREE NOW does not own, control, offer or manage any Listings or Services. FREE NOW is not a party to the contracts entered into directly between Providers and Renters and FREE NOW is not acting as an agent in any capacity for any Platform user. “FREE NOW Group“ consists of Intelligent Apps GmbH, mytaxi Austria GmbH, Free Now Ireland Limited, mytaxi Italia Sr., mytaxi Polska Sp.z.o.o, mytaxi Iberia S.L., Clever Tech Srl., Transcovo SAS, Transopco SAS, Transopco UK Ltd., FREE NOW Portugal Unipessoal Lda.
DATA PROCESSING ACTIVITIES AND PURPOSES In the following, we will inform you about the various types of personal data we process and for what purpose. The FREE NOW Taxi Marketplace facilitates introduction of Taxi Renters to Taxi Providers for the purposes of concluding a contract between the parties outside of the Platform. 3.1 Personal Information We Collect. 3.1.1 Information Needed to Use the Platform. We collect personal information about you when you use the Platform. Without it, we may not be able to provide all services requested. This information includes: 3.1.1.1 Account and Profile Information. Such as your first name, last name, phone number, postal address, email address, date of birth, and profile photo, some of which will depend on the features you use. 3.1.1.2 Identity Information. Where appropriate, we may ask you for an image of your government-issued ID (in accordance with applicable laws) or other verification information, and/or a selfie when we verify your ID. If a copy of your ID is provided to us, we will obtain information from your ID. 3.1.2 Information You Choose to Give Us. You can choose to provide us with additional personal information, including: 3.1.2.1 Additional Profile Information. Such as a personal description. 3.1.2.2 Additional Product Information. Such as photo of vehicle which may include roof sign, vehicle registration number. 3.1.2.3 Other Information. Such as when you fill in a form, add information to your account, respond to surveys, post to community forums, participate in promotions, communicate with FREE NOW Support and communicate with other Platform users. 3.1.3 Information Automatically Collected by Using the Platform. When you use the Platform, we automatically collect certain information. This information may include: 3.1.3.1 Geolocation Information. Such as location determined from your IP address, mobile or other device’s GPS, or other information you share with us, depending on your device settings.. 3.1.3.2 Usage Information. Such as searches for listings, additional services you have added, access dates and times, and messages you have exchanged on the platform. 3.1.3.3 Device Information. Such as IP address, hardware and software information, device information, device event information, unique identifiers, crash data. 3.1.3.4 Cookies and Similar Technologies As Described in Our Cookie Policy

3.1.4 Information we Collect from Other Sources. We may collect personal information from other sources, such as: 3.1.4.1 Third-Party Applications. If you choose to link, connect, or login to the Platform with a third-party service (e.g. Facebook), you direct the service to send us information such as your registration, and profile information as controlled by that service or as authorized by you via your privacy settings at that service. 3.1.4.2 Background Information Providers. To the extent permitted by applicable laws and with your consent where required, we may obtain police, and/or background information on you. We may use your information, including your full name and date of birth, to obtain such reports. 3.1.4.3 Complainants. If another platform user, or any third party submits a complaint about you, we may receive information relating to the specific complaint made in order to understand and, where relevant, address the complaint. 3.1.4.5 Other Sources. To the extent permitted by applicable law, we may receive additional information about you, such as references, demographic data, and information to help detect fraud and safety issues. 3.1.5 Contact with FREE NOW. FREE NOW provides several means of contact for its customers such as our online contact form, letter or phone. Our legal basis for processing is our legitimate interest, according to Art. 6 (1) f) GDPR, in responding to your messages. Whenever you get in touch with FREE NOW, we store and process your personal data. 3.1.5.1 Data Processed when using our online form: to use our online form you are only required to provide us with your e-mail address for us to respond to your message. 3.1.5.2 Data Processed for other methods of Support: if you contact us by letter our phone we may process your name, e-mail address, country, phone number, voice recordings, content of your messages, attachments. 3.1.5.3 Data Processed for Contract-related Support: when you initiate a contact to enter into a contract or because of a contract with FREE NOW, our legal basis is Art. 6 (1) b) GDPR. 3.1.5.4 Data Retention. Communication with FREE NOW is deleted after 3 years, based on our legitimate interest, Art. 6 (1) f) GDPR, for the establishment, exercise or defence of legal claims. Call recordings get automatically deleted after 90 days.

3.2 Sub-processors From time to time FREE NOW engages certain third-parties as sub-processors to provide services related to the Platform. 3.2.1 Hosting of the Platform: we use the services of EU-based Sharetribe Oy (Finland) to host the FREE NOW Taxi Marketplace. In addition to the data collected by us on the Platform, Sharetribe automatically collects and processes the following technical data about Platform users: IP address, Geographical location data based on the IP address, Service access times, Statistics on page views, Any other automatically collected technical data. Furthermore, Sharetribe may also collect other anonymized statistics about the way the User uses the Services provided by Sharetribe.

3.2.2 Provision of Support: In order to offer our best service to you, we are working together with Zendesk, Inc. 1019 Market Street, San Francisco, CA 94103, USA. The transmission of your personal data is secured by Standard Contractual Clauses and Binding Corporate Rules in accordance with Art. 46 GDPR. Username (which may or may not be the individual's actual name), Email address, IP address, Date and time of events, Any text entered into free form text fields, Any data contained in attachments. Learn more about Zendesk and their commitment to the protection of personal data at https://www.zendesk.com/company/privacy-and-data-protection. 3.2.3 Sending of news and service communications: For sending news, service communication and advertising e-mails, SMS we make use of the service provider Braze Inc., 330 West 34th Street, New York, NY 10001, USA (“Braze”). For sending service communications, we make use of the service provider “MailChimp“, which is operated by Rocket Science Group, LLC, 675 Ponce De Leon Ave NE, Suite 5000, Atlanta, GA 30308, USA. The personal data processed includes contact data, e.g. e-mail address, phone number, name, location data, e.g. language, country, city, content data, e.g. tour data, incentives data, usage data, e.g. log-in times, log-out times. 4. DATA EXCHANGE WITHIN THE FREE NOW GROUP

For internal administration and standardization purposes, we may transfer personal data of taxi providers, taxi renters, drivers or passengers within the FREE NOW Group. The legal basis for this is our legitimate interest, Art. 6 (1) f) GDPR, see also Recital 48 to the GDPR. 4.1 Joint Controller Agreement FREE NOW has entered into a Joint Controller Agreement according to Art. 26 GDPR with Intelligent Apps GmbH, Grosse Elbstrasse 273, 22767 Hamburg, Germany (“Intelligent Apps”). The Parties have jointly determined the order of the process-ing of your personal data in each section of processing. The purpose of this agreement is to further enhance the development of the FREE NOW Platform, to improve our service levels, to improve the processing of customer enquiries and to improve the handling of personal data. The Parties jointly agreed on which obligations each party fulﬁls under the GDPR. Despite the existence of a joint controllership, the Parties fulﬁl the obligations under data protection law in accordance with their respective competences. The Parties shall provide any information referred to in Articles 13 and 14 GDPR to you free of charge in a concise, transparent, intelligible and easily accessible form, using clear and plain language. For this purpose, each Party shall provide the other Party with all necessary information relating to their respective operating range. The Parties shall immediately inform each other about the exertion of your rights and provide the other Party with all necessary information referred to the right of access. Pursuant to Articles 15 through 22 GDPR, you may exercise your rights under the GDPR in respect of and against each of the Parties. However, to speed up the response, we would kindly ask you to contact FREE NOW to exercise your rights via https://support.free- now.com/hc/en-ie/requests/new . For more information on data processing by Intelligent Apps, please refer to the information provided in both German and English in the in the German Privacy Policy at https://free- now.com/de/pp-driver/

PROCESSING INSIDE/OUTSIDE OF THE EUROPEAN UNION/ EUROPEAN ECONOMIC AREA In part, we arrange for external service providers to process your data (e.g. troubleshooting, creation of mailings). To this end it is necessary for us to transmit your personal data to our external service providers for a speciﬁed purpose (conﬁned to the purpose in question). We have selected our service providers carefully and engaged them in writing. They are bound by our instructions and we have obtained information about their technical and organizational measures for the se-cure processing of personal data. We also require that our service providers comply with the applicable data protection regulations. We work with service providers from the EU and EEA countries. We have concluded data processing agreements with our external service providers in accordance with Art. 28 (3) GDPR, inasmuch as this is required for the contractual purpose. The transfer to service providers outside of the European Economic Area takes place correspondingly on the basis of decisions by the EU Commission pursuant to Art. 45 GDPR or on the basis of standard EU contractual clauses. We store all our data with a cloud service provider within the EU or in IT infrastructures and systems (employee computers) at our sites within the EU. However, we do reserve the right to disclose information about you if we are legally obligated to do so or if we are asked to surrender it by administrative or law enforcement bodies (e.g. police or state prosecutors).
YOUR RIGHTS You have the right to obtain conﬁrmation as to whether or not personal data concerning you is being processed by us. Where this is the case, we will be pleased to give you access to the personal data and the information listed in Art. 15 GDPR. In addition, you have the right to rectiﬁcation (Art. 16 GDPR), the right to erasure (Art. 17 GDPR), the right to restriction of processing (Art. 18 GDPR) and the right to data portability (Art. 20 GDPR), subject to the relevant legal requirements. In addition, you have the right to object to the processing under the statutory conditions (Art. 21 GDPR) or to withdraw any consent you have given at any time with effect for the future (Art. 7 (3) GDPR). In order to assert your rights against us, it is sufﬁcient to send a message via https://support.free-now.com/hc/en-ie/requests/new or a postal letter to the address mentioned under “1. Information regarding the Data Controller” above. In addition, you may at any time lodge a complaint with a competent supervisory authority if you consider that the processing of your personal data infringes data protection regulations (Art. 77 GDPR). The relevant supervisory authority for Ireland is: Data Protection Commission 21 Fitzwilliam Square South Dublin 2, D02 RD28 Website: https://www.dataprotection.ie/
DATA SECURITY We have taken appropriate technical and organizational measures to guarantee data security, in particular to protect your personal data against access by third parties, as well as accidental or intentional modiﬁcation, loss or destruction. Such measures are reviewed periodically and adapted in line with the state of the art. The transfer of your personal data from your end user device (e.g. smartphone) to us is always encrypted.
STORAGE PERIOD The data provided by you to us is only stored for as long as is required to perform the respective purpose for which you have transmitted your data, or inasmuch as it is required for conformity with statutory or ofﬁcial requirements. Personal data is anonymized by us, in principle, after three years, unless we have a legitimate interest in a longer storage period (e.g. book-keeping requirements).
UPDATES AND CHANGES We retain the right to modify this privacy policy at any time in the future in accordance with the applicable data protection regulations.